Shaftesbury Capital PLC

Shaftesbury Capital PLC has implemented a structured governance framework for its climate lobbying by establishing the Environment, Sustainability and Community ("ESC") Management Committee to oversee all direct and indirect activities that influence climate change policy. As the company states, "The ESC Management Committee manages the Group's day to day ESC activities and is responsible for ensuring that any direct and indirect activities that influence climate change policy are firmly aligned with the ESC Strategy and business strategy." This committee, which includes the "Group's Director of Sustainability and Technology" and "a designated Non-executive Director (who also Chairs our Board ESC Committee)," reviews "any proposed activities with the intention of influencing climate change policy" and requires that they "must be reported to the ESC Management Committee for approval prior to implementation" to ensure alignment with the company's climate change strategy. Meeting quarterly with "formal meeting papers and minutes of the decisions made during the meeting," the committee reports to ExCo and the Board, demonstrating a clear process and lines of accountability. While the company integrates climate considerations into its supplier code of conduct and publishes regular sustainability reporting such as its Annual Report and Sustainability Data Report, we found no evidence of a standalone, publicly available audit or review specifically dedicated to assessing the alignment of its climate-related lobbying activities.