Swedish Orphan Biovitrum AB

Swedish Orphan Biovitrum AB provides very limited insight into how it governs its lobbying activities. The only disclosure that directly touches on climate-related advocacy is its acknowledgement that it has a "public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement - Yes," which signals an intention to align any policy engagement with climate goals but does not explain how this is implemented or overseen. Other governance descriptions - for example the "Corporate compliance committee, consisting of the CEO, CFO, General Counsel, and Chief Compliance Officer, [which] oversees compliance investigations" and the statement that the "Global Compliance Governance Charter ensures the management oversight of the compliance programme" - relate to general compliance, anti-corruption and whistle-blowing rather than to lobbying or trade-association engagement. The company does not disclose any mechanism for monitoring or approving its direct or indirect lobbying, does not identify a board or executive body charged with reviewing lobbying alignment, and does not report on trade-association positions or corrective actions. Accordingly, while a high-level commitment to Paris-aligned engagement is declared, the absence of any disclosed processes or oversight specific to lobbying indicates only limited governance in this area.