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.

more less

"She is an outstanding lawyer and a pleasure to work with."

Chambers, 2023


  • 2001 – Legal Practice Course, College of Law
  • 2000 – LL.B Law, University of Newcastle-upon-Tyne
more less



Food Con­tact Ma­ter­i­als (FCM) - New EU rules on re­cycled plastic ma­ter­i­als...
On 10th Oc­to­ber 2022 (next week), Reg­u­la­tion (EU) 2022/1616 on re­cycled plastic ma­ter­i­als and art­icles in­ten­ded to come in­to con­tact with foods (im­ple­men­ted earli­er in the year) is due to come in­to force...
The fu­ture of food la­belling? Cur­rent evid­ence on front-of-pack nu­tri­tion...
As part of its Farm to Fork Strategy, the European Com­mis­sion in­tends to in­tro­duce man­dat­ory front-of-pack nu­tri­tion la­belling in the European Uni­on (“EU”) by the end of this year. Ahead of this...
EU and UK de­vel­op­ments on the road to­wards a sus­tain­able and cir­cu­lar eco­nomy...
A re­cent re­search pa­per co-au­thored by WRAP and the Uni­versity of Sur­rey[1] found that the im­ple­ment­a­tion of dif­fer­ent busi­ness mod­els in the tex­tiles in­dustry (such as cloth­ing re­sale busi­nesses, cloth­ing...
The European Green Deal in ac­tion: sig­ni­fic­ant new cir­cu­lar eco­nomy meas­ures...
On 30 March 2022, the European Com­mis­sion (“EC”) presen­ted a pack­age of meas­ures in­ten­ded to make sus­tain­able products the norm in the EU, fa­cil­it­ate cir­cu­lar busi­ness mod­els and em­power con­sumers...
En­vir­on­ment Bill be­comes law
On 9 Novem­ber 2021, the long-awaited En­vir­on­ment Bill (the “Bill”) fi­nally re­ceived roy­al as­sent, be­com­ing the En­vir­on­ment Act 2021 (the “Act”). The Act es­tab­lishes a leg­al frame­work for en­vir­on­ment...
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.