The United Nations Framework Convention on Climate Change asserts that greenhouse gas emissions must decline by 43 percent from 2019 levels by 2030 and 65 percent by 2035 to avert the worst impacts of climate change, including more frequent and severe droughts, heatwaves, and rainfall.[1]

Mondelez (“Company”) has laid out the strategic, operational, and reputational risks that climate change impacts may have on its business.[2] In response, the Company has publicly committed to a 2050 net zero emissions target that has been validated by the Science Based Targets Initiative and supports its Vision 2030 growth strategy.[3] Although Mondelez has disclosed efforts to make progress against its sustainability and climate goals, it acknowledges that the Company’s ability to meet such goals are subject to evolving regulatory requirements and to the availability of suppliers that can meet the Company’s standards.[4] However, Mondelez provides insufficient transparency about its lobbying activities, making it challenging for investors to evaluate whether and how the Company’s advocacy efforts are supportive of and consistent with its net zero goal and its three key drivers for reducing carbon emissions.

Mondelez has spent approximately $9 million on federal lobbying since 2014.[5] This does not include state lobbying, where Mondelez also lobbies but disclosure is uneven or absent. The Company’s disclosure is limited to a list of broad advocacy areas of focus and a list of memberships in trade associations with annual dues of $50,000 or more. In contrast, Unilever[6] provides a much more informative description of its policy influence activities, including an assessment of alignment of Unilever’s lobbying activities with its positions on climate policy.

Corporate lobbying that contradicts a company's own commitments can damage a brand’s value and lead to negative financial consequences.[7] Furthermore, delays in emissions reductions, increases the probability of physical risks to assets, abrupt policy changes, and limited access to capital and insurance.

Of particular concern is Mondelez’ membership in a trade association that has advocated negatively on multiple forms of climate policy.[8]