Home / People / Alex Ibrahim
Portrait of Alex Ibrahim

Alex Ibrahim

Of Counsel

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
United Kingdom
Languages English

Alex Ibrahim is an Of Counsel in the Environment team. Alex has extensive experience in advising clients on the acquisition and divestment of sites with complex environmental issues and on developing strategies for the mitigation/management of the associated risks, including the use of environmental insurance. She has undertaken due diligence for clients in a range of heavily regulated sectors including waste, chemicals and manufacturing.  Alex often works closely with technical consultants to identify and assess the potential environmental legal liabilities associated with sites and business operations.

With more than 450 energy and climate change lawyers, including over 100 partners, the CMS Energy and Climate Change practice is one of the largest of its kind in the world. Led from its centres of excellence such as London and Aberdeen, the practice works across 75 offices globally. Building on 40 years of experience advising on power, oil & gas and renewables through to energy disputes, emerging areas and Energy Transition, CMS is uniquely placed to ensure clients receive advice best suited to their commercial needs and to our collective future.

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  • 2001 – Legal Practice Course, College of Law
  • 2000 – LL.B Law, University of Newcastle-upon-Tyne
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The me­dia and cli­mate change
How is the me­dia sec­tor ad­dress­ing the cli­mate chal­lenge?
Ded­ic­ated En­ergy & Cli­mate Change prac­tice
With more than 450 law­yers in 75 of­fices across the globe our En­ergy and Cli­mate Change prac­tice is one of the largest of its kind. It was foun­ded on ground-break­ing work design­ing and im­ple­ment­ing mod­ern en­ergy mar­kets and is now at the fore­front of de­vel­op­ments on en­ergy trans­ition, re­new­ables and the vari­ous re­sponses to the cli­mate crisis. From ad­vising on cli­mate change strategy, new tech­no­lo­gies, risk and dis­putes, to en­vir­on­ment­al reg­u­la­tion, Power Pur­chase Agree­ments, and real es­tate and in­fra­struc­ture pro­jects, we ad­vise cli­ents op­er­a­tion­ally and stra­tegic­ally. Our track re­cord in­cludes: Ad­vising on the UK’s most ad­vanced car­bon cap­ture pro­ject in the UK’s first zero-car­bon in­dus­tri­al cluster. BP, Eni, Equi­nor, Shell and Total have formed a con­sor­ti­um and as­sumed lead­er­ship of the Net Zero Teesside Pro­ject, pre­vi­ously known as the Clean Gas Pro­ject.Ad­vising product man­u­fac­tur­ers in re­la­tion to sus­tain­ab­il­ity laws for on the launch of new broad­cast and stream­ing devices.Ad­vising broad­cast­ing and me­dia pub­lish­ing com­pan­ies in re­la­tion to Stream­lined En­ergy and Car­bon Re­port­ing and the En­ergy Sav­ings Op­por­tun­ity Scheme.Ad­vising vari­ous private equity funds, banks and large in­ter­na­tion­al man­u­fac­tur­ing and real es­tate or­gan­isa­tions such as Columbia Thread­needle In­vest­ments, Amet­ek, and John La­ing In­fra­struc­ture Fund on en­ergy ef­fi­ciency, car­bon and re­lated re­port­ing ob­lig­a­tions across the EU.Ad­vising ma­jor banks, in­surers and as­set man­agers on prin­ciples likely to un­der­pin reg­u­lat­ory frame­works in­clud­ing, EU Ac­tion Plan for Fin­an­cing Sus­tain­able Growth, Fin­an­cial Sta­bil­ity Board’s Task Force on Cli­mate-re­lated fin­an­cial dis­clos­ures, LMA Green Loan Prin­ciples, ICMA Green Bond prin­ciples.
Get­ting the mes­sage across
For me­dia com­pan­ies, the twin re­spons­ib­il­it­ies of work­ing to­wards net zero and of con­vey­ing the im­port­ance of that mes­sage to their view­ers, read­ers and con­sumers re­quires a care­fully cal­ib­rated ap­proach. In a sec­tor gen­er­ally char­ac­ter­ised by a high level of com­pet­i­tion, the level of co-op­er­a­tion and col­lab­or­a­tion between the ma­jor par­ti­cipants serves as a role mod­el for oth­ers to fol­low.Glob­al suc­cess at COP26 will ul­ti­mately be judged by gov­ern­ments’ col­lect­ive ef­forts to achieve their goals. Sim­il­arly, the me­dia sec­tor may well be judged by its abil­ity to com­mu­nic­ate and per­suade people to change their be­ha­viour. It is a re­spons­ib­il­ity they seem well-equipped to man­age and one that CMS is act­ively en­gaged in help­ing with.
Cli­mate change cov­er­age
However well the me­dia sec­tor per­forms in work­ing to­wards its zero car­bon tar­gets by re-eval­u­at­ing in­tern­al pro­cesses and cor­por­ate be­ha­viour, its greatest be­ne­fi­cial im­pact ar­gu­ably rests in its ca­pa­city to change so­ci­et­al and con­sumer be­ha­viour. Here, the me­dia sec­tor has an enorm­ous part to play – through por­tray­als on screen, in TV shows, news pro­grammes such as Sky’s The Daily Cli­mate Show and doc­u­ment­ar­ies, as well as in ad­vert­ising. Where broad­casters used to give cli­mate change den­iers equal air­time in dis­cus­sions on the top­ic, this is no longer the case. Some TV pro­grammes, des­pite per­haps hav­ing a re­l­at­ively heavy car­bon foot­print, have served to get im­port­ant mes­sages about cli­mate change across to many mil­lions of people. To film a nature doc­u­ment­ary, the crew has to take their equip­ment to far flung places, of­ten for weeks or months at a time. However, the be­ne­fi­cial im­pact of these pro­grammes can dwarf the car­bon foot­print in­volved in mak­ing them. The net be­ne­fit of some of these pro­duc­tions – Blue Plan­et II be­ing an ob­vi­ous ex­ample – has there­fore been ex­po­nen­tially high­er than the ac­tu­al car­bon foot­print cre­ated be­cause they have edu­cated so many people about the hor­rendous im­pact of cli­mate change on an­im­al and hu­man hab­it­ats. ‘ITV takes is­sues which are on the edge of the main­stream and makes them main­stream,’ says Braun. When it comes to mak­ing cli­mate change main­stream, noth­ing can sur­pass COP26 which is to be hos­ted by the UK in Glas­gow. COP is short­hand for con­fer­ence of the parties un­der the United Na­tions Frame­work Con­ven­tion on Cli­mate Change (UN­FC­CC). This year’s meet­ing, COP26, will of­fi­cially open on 31 Oc­to­ber with more than 120 world lead­ers at­tend­ing as they seek to find ways to re­duce GHG emis­sions and de­liv­er on the am­bi­tions set out in the Par­is Agree­ment and the Con­ven­tion. Un­der the 1992 UN­FC­CC, every coun­try is treaty-bound to “avoid dan­ger­ous cli­mate change”. ‘We talk about our so­cial pur­pose plans at ITV, our abil­ity as a plat­form to re­flect and shape cul­ture,’ says Braun. ‘On the first day of COP26, we’ve got Cli­mate Ac­tion Day on ITV, our main chan­nel. So, from six o’clock in the morn­ing through to 10:30 at night, the en­tire day is go­ing to have a cli­mate ac­tion theme with­in the pro­grammes and the ad­vert­ising breaks.’
Live sport
When the pan­dem­ic hit BT Sport, they de­cided to ac­cel­er­ate re­mote pro­duc­tion. ‘A foot­ball match, pre-pan­dem­ic, nor­mally in­volved sev­er­al out­side broad­cast vehicles,’ says Garber. ‘For ex­ample, one for the slow-mo­tion re­plays, a second to man­age the present­a­tion and a third to cov­er the match: the dir­ect­or call­ing the cam­er­as. In ad­di­tion to these size­able vehicles, there is a tender, which car­ries all the equip­ment, a din­ing bus, and an­oth­er to man­age on­screen graph­ics. They have to ac­com­mod­ate a very large TV crew. Be­cause of tech­no­logy en­hance­ments, many of these people and their kit can now be some­where else. ‘So, you send your cam­era team, presenters and com­ment­at­ors, but al­most every­body else – re­plays, graph­ics, dir­ect­or, pro­du­cer and as­sist­ant pro­du­cers – can be hun­dreds of miles away in a pro­duc­tion con­trol room. We call them Re­mote Op­er­a­tions Centres (ROCs), like out­side broad­cast trucks, but with no wheels. You have an ROC in a cent­ral loc­a­tion which the crew go to match after match, in­stead of trav­el­ling all over the coun­try. That’s re­mote pro­duc­tion. In ad­di­tion to our Strat­ford stu­dio, we plan to build centres in Birm­ing­ham, Leeds and Glas­gow. So we can still use the people we want, but they have less dis­tance to travel. Crew travel and kit move­ments have been much re­duced: that’s been a very pos­it­ive sus­tain­ab­il­ity by-product of the pan­dem­ic.’In a sign that the trend is spread­ing fur­ther in­to sport, Sky and Tot­ten­ham re­cently partnered for the world’s first ma­jor net zero car­bon foot­ball game against Chelsea. Pub­li­city for the Premi­er League match in­cluded the fol­low­ing: ‘#GameZero will demon­strate the green steps that the sport­ing world can take to work to­wards a zero­car­bon fu­ture; #GameZero part­ners want the game to raise aware­ness of the threat of cli­mate change and in­spire fans to make simple changes that will help re­duce their car­bon foot­print.'
Ad­vert­ising: pro­act­ive steps
As one of the key reg­u­lat­ors in the me­dia sec­tor, The Ad­vert­ising Stand­ards Au­thor­ity (ASA) has, his­tor­ic­ally, been more re­act­ive than pro­act­ive. But this has changed. ‘The move from re­act­ive to pro­act­ive is a jour­ney we’ve been on since 2014,’ says Guy Park­er, the ASA’s Chief Ex­ec­ut­ive. ‘We’ve made really big strides. Far less of our re­source is now spent deal­ing re­act­ively with com­plaints from the pub­lic.’ Part of that shift in­volves cli­mate change. ‘For the ASA, the fo­cus is: what con­tri­bu­tion should ad­vert­ising reg­u­la­tions make to us hit­ting the cli­mate change tar­gets that we have set ourselves, which have be­come more de­mand­ing with the 78% car­bon re­duc­tion by 2035 tar­get,’ he says. The chal­lenge, notes Park­er, is to identi­fy the pri­or­ity areas that the ASA should look at. ‘Where hu­mans are con­trib­ut­ing to bad en­vir­on­ment­al im­pacts: avi­ation, food, cars and heat­ing are four big areas that have been iden­ti­fied as pri­or­it­ies for be­ha­vi­our­al change in vari­ous re­ports by the Cli­mate Change Com­mit­tee, among oth­ers,’ he says. ‘That gives us a steer on where we should be look­ing.’ Park­er adds: ‘The ASA tries to re­flect so­ci­ety, rather than so­cially en­gin­eer so­ci­ety. This gov­ern­ment and fu­ture gov­ern­ments are go­ing to be leg­ally held to some in­cred­ibly de­mand­ing cli­mate change tar­gets. That makes our life easi­er be­cause the case for change has been made. We then have to de­cide, look­ing at the evid­ence, be­ing thought­ful, tak­ing sound­ings from ex­perts, what that change looks like. There’s a le­git­im­ate ques­tion about wheth­er ad reg­u­la­tion needs to play a part in that change. Busi­nesses want to do the right thing, and pro­mote more sus­tain­able be­ha­viour, not be­cause they’re held to that by a code that we po­lice, but be­cause it fits with their ESG strategy, their com­mit­ments, and their con­tracts with their con­sumers.’ Last Novem­ber, the Ad­vert­ising As­so­ci­ation (AA) launched its Ad Net Zero plan, which aims to get the ad­vert­ising in­dustry to com­mit to min­im­ise its car­bon foot­print in the cre­ation of ads. This year, the ASA and CAP are un­der­tak­ing a Cli­mate Change and the En­vir­on­ment pro­ject, tak­ing stock of the rules reg­u­lat­ing en­vir­on­ment­al claims (some guid­ance hav­ing re­cently been is­sued by the CMA). ‘We’re not just look­ing at green claims, we’re also look­ing at broad­er en­vir­on­ment­al mes­sages, un­sus­tain­able con­sumer be­ha­viours, the ex­tent to which ad­vert­ising is con­trib­ut­ing to that,’ says Park­er. ‘In the next few years, it will be uni­ver­sally ac­cep­ted that ad reg­u­la­tion has a role to play, where it doesn’t at the mo­ment.’ But there is only so much that the ASA can do, even on a more pro­act­ive basis without le­gis­lat­ive change. Stu­art Helmer, head of ad­vert­ising and mar­ket­ing at CMS Lon­don, com­ments: “We have seen reg­u­lat­ors, in­clud­ing the ASA, tak­ing a firmer line against un­sub­stan­ti­ated en­vir­on­ment­al claims in re­cent years. Of­ten this be­ne­fits big brands, who can get wild claims of­ten made by dis­ruptor com­pan­ies taken down. But a re­align­ment of ad­vert­ising reg­u­la­tion to dis­cour­age over­con­sump­tion gen­er­ally would be a sig­ni­fic­ant step bey­ond the ASA’s nor­mal func­tion of cur­tail­ing mis­lead­ing ad­vert­ising, and could have far-reach­ing ef­fects on the in­dustry. While there is only so much that the ASA can do, even on a more pro­act­ive basis, without le­gis­lat­ive change, the CMA’s re­cent pub­lic­a­tion of guid­ance on gre­en­wash­ing may in­dic­ate a firmer line from the ASA’s “back­stop” reg­u­lat­or. Ad­vert­isers should keep a close eye on the out­come of the ASA re­view.”
In­tern­al fo­cus
ITV has form­al­ised its net zero tar­get in an an­nu­al pro­duc­tion plan. ‘We’ve in­stalled an en­vir­on­ment­al data plat­form which provides trans­par­ency on our car­bon emis­sions,’ says Braun. ‘It’s very de­tailed work and quite painstak­ing: we need to look at emis­sions from of­fices based in 13 ter­rit­or­ies around the world which might have mul­tiple sites. In the UK, we have more than 110 sites.’ Garber out­lines BT Sport’s ap­proach. ‘It’s im­port­ant to start from the top down,’ he says. ‘We put our seni­or lead­er­ship team through car­bon lit­er­acy aware­ness train­ing, which has an im­me­di­ate im­pact on how they view their place in the world and how they can help. Train­ing is ex­tremely im­port­ant to get every­body on board. Train the seni­or team, then work down. Al­bert was very help­ful be­cause they provide free train­ing to the me­dia in­dustry. Once that hap­pens, every­body is play­ing for the same team in try­ing to make a dif­fer­ence. Then you do simple things, like giv­ing every­body a flask and a cof­fee cup. ‘Our core busi­ness is sports pro­duc­tion. How do you pro­duce the con­tent? The first thing is to ap­ply everything you do in the stu­dio to when you’re out on the road or mak­ing pro­grammes – at out­side broad­casts, things like ca­ter­ing, single use plastic.’ It’s really im­port­ant to bring your sup­ply chains with you, he notes. ‘The worst thing is to say to your sup­pli­ers: we’re sus­tain­able now, so you’ve got to be. End of con­ver­sa­tion. That’s not the way to do it. In­stead, tell them: we’re a sus­tain­able com­pany now, or cer­tainly try­ing to be, we’d love it if you were too. Let’s see how we can work to­geth­er to get you to a point that we’re all happy with.’ Go­ing green ‘isn’t free’, he notes, ‘it costs someone money some­where.’ This year, Garber re­ceived a press re­lease from Sky Sports about their tar­get to go 100% Green D Plus bio­fuel in out­side broad­cast gen­er­at­ors in a mat­ter of weeks. ‘I sent an email to the head of sus­tain­ab­il­ity at Sky and said: this is amaz­ing, how are you go­ing to do it? She sent me the de­tails of their ac­tion plan. I phoned Tele­gen­ic – our out­side broad­cast sup­pli­er – and said: Can we do what Sky is do­ing? Tele­gen­ic said: yes, we can. Six weeks after their ini­tial press re­lease, we hit the same tar­get as Sky. It’s so im­port­ant that we share know­ledge across the sec­tor even if we’re com­pet­it­ors.’ But, Garber cau­tions: ‘We’ve got to be care­ful not to preach. We re­cog­nise we’re not per­fect and shouldn’t pre­tend that we are. The crime is say­ing noth­ing be­cause you’re too frightened you will be caught out.’ At a prac­tic­al level, both ITV and BT Sport would ideally like their staff and freel­an­cers to use elec­tric vehicles. But un­til the up-front cost drops and the range of EVs in­creases this is not yet feas­ible.
Cal­cu­la­tion in prac­tice
‘Al­bert has helped us,’ says Fer­gus Garber, Dir­ect­or of Pro­duc­tion at BT Sport. ‘The prin­ciple of award­ing a sus­tain­ab­il­ity cer­ti­fic­ate – and be­ing able to at­tach it to the cred­its as a badge of hon­our for your pro­gramme – is very clev­er: it’s what all the broad­casters want. It’s a huge achieve­ment when you get one since it really in­centiv­ises the pro­duc­tion com­pan­ies to be green­er, to achieve that cer­ti­fic­ate.’ Braun adds: ‘Al­bert cer­ti­fic­a­tion is what we man­date all ITV Stu­di­os pro­grammes and all of our com­mis­sioned pro­grammes to go through. The Al­bert sys­tem is smart in its sim­pli­city and prac­tic­al in a very gran­u­lar way. At the be­gin­ning of a pro­duc­tion, you use their car­bon cal­cu­lat­or, es­tim­ate what your car­bon foot­print will be by put­ting in the num­ber of days you’ll be in an edit suite, or the num­ber of flights you might take. If you’re shoot­ing abroad, the ho­tels you’re stay­ing in. That pro­duces your car­bon foot­print. ‘You then need to de­term­ine how it can be re­duced. That might be re­du­cing travel, chan­ging the way that the pro­duc­tion is filmed to give you few­er days, for ex­ample. You sub­mit your new car­bon foot­print, which shows the re­duc­tions you’ve im­ple­men­ted. You then have to off­set through the Al­bert off­set­ting scheme, run by Nat­ur­al Cap­it­al Part­ners, and provide BAF­TA with evid­ence of what you’ve done. ‘In work­ing with our pro­cure­ment team, we’ve taken our top 200 emit­ters: how much we are spend­ing with them and cal­cu­lat­ing what the emis­sions factor will be as a res­ult. We then looked at those 200 sup­pli­ers in more de­tail, ask­ing each of them: Can you tell us about your cli­mate ac­tion plan? Do you have a net zero plan? What are you do­ing to re­duce your car­bon? Are you run­ning on re­new­able en­ergy?’ This can then be factored in­to con­tract ne­go­ti­ations. ‘Bey­ond re­cog­nising car­bon net zero as an ob­ject­ive, me­dia or­gan­isa­tions – along with all com­pan­ies – work­ing with their sup­pli­ers to re­duce their car­bon foot­print need to know what they should put in­to their con­tracts to achieve the de­sired out­comes and mon­it­or pro­gress, as well as know­ing what kinds of con­tracts they might start to see that they haven’t seen be­fore’ says Vic­tor­ia Gaskell, co-head of the me­dia prac­tice at CMS.
So, what are me­dia com­pan­ies do­ing to ad­dress the chal­lenge of meet­ing these tar­gets at a cor­por­ate level? Their re­sponse is cal­ib­rated to ac­com­mod­ate two dis­tinct ele­ments: the activ­it­ies of me­dia com­pan­ies them­selves and those of their sup­pli­ers and freel­an­cers, who com­prise a sig­ni­fic­ant por­tion of work­ers in this sec­tor, par­tic­u­larly in pro­duc­tion and journ­al­ism. A con­cer­ted ef­fort ex­ists among the ma­jor broad­casters to ad­dress both with equal vigour. Earli­er this year, Net­flix pledged to achieve net zero GHG emis­sions by the end of 2022. In com­mon with the BBC, Sky and Chan­nel 4, ITV has a net zero emis­sions tar­get by 2030. ‘It’s been ap­proved by the Sci­ence Based Tar­gets ini­ti­at­ive (SBTi),’ says Susie Braun, Dir­ect­or of So­cial Pur­pose at ITV. ‘We look at our com­pet­it­ors in terms of tar­gets they might set for pro­grammes they’re com­mis­sion­ing to un­der­stand how suc­cess­ful they are, and which audi­ence they reach,’ she says. But on cli­mate change and the me­dia sec­tor’s re­sponse to it, col­lab­or­a­tion is seen as key. ‘On cli­mate ac­tion, the TV sec­tor is in­cred­ibly col­lab­or­at­ive,’ says Braun. ‘We share so many of the same sup­pli­ers: it doesn’t make sense to set dif­fer­ent stand­ards for a small pro­duc­tion com­pany to meet Sky’s stand­ards, but not ITV or BBC stand­ards. We want to make it easy for sup­pli­ers to meet stand­ards that we need them to meet. We work to­geth­er with them to achieve that.’ She adds: ‘All the broad­casters meet un­der the Al­bert aus­pices when it comes to sus­tain­ab­il­ity. We are very happy to share in­form­a­tion and work to­geth­er to achieve our aims.’John En­ser, me­dia part­ner at CMS, ex­plains: ‘For broad­cast­ing, the key or­gan­isa­tion is Al­bert, which does all the cer­ti­fic­a­tion.’ Foun­ded in 2011 and gov­erned by an in­dustry con­sor­ti­um un­der the ae­gis of BAF­TA, Al­bert is a sus­tain­ab­il­ity pro­ject, which acts as the au­thor­ity on en­vir­on­ment­al sus­tain­ab­il­ity for film and TV. Its dir­ect­or­ate mem­bers are BBC, ITV, Chan­nel 4, Sky, Net­flix and BT Sport. Crit­ic­ally, Al­bert provides a sys­tem of car­bon cal­cu­la­tion and sus­tain­ab­il­ity cer­ti­fic­a­tions for me­dia com­pan­ies.