H Lundbeck A/S

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	H. Lundbeck A/S has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly named specific climate policies it has engaged with, such as the "Energy Agreement of 29 June 2018 relating to surplus heat," "Agreement on increased utilization of surplus heat of 28 March 2019," "Climate agreement for energy and industry etc. of 22 June 2020," "Waste regulation no 2159 of 09/12/2020," and the Danish government's new agreement on carbon tax. These disclosures include detailed information about the context, focus, and geography of the policies, as well as the company's position on them. Lundbeck has also provided detailed information about its lobbying mechanisms, including participation in the Danish government's climate partnership for the Life Science and Biotech sector, where it engaged in activities such as filling out questionnaires, attending seminars, and commenting on recommendations and sector roadmaps. The company identifies specific targets of its lobbying efforts, such as the Danish government and specific ministers. Furthermore, Lundbeck has been transparent about the specific policy outcomes it seeks to achieve, including recommendations to "remove the excess heat charge and adjust the electric heating tax," "adjust regulation for recycling of excess heat," and "create a better and clearer framework for recycling of waste." It also advocates for a green tax reform with stable framework conditions, supports electrification and conversion away from gas, and proposes a high CO2 tax price signal of DKK 1000/tCO2. These disclosures illustrate Lundbeck's comprehensive approach to climate lobbying transparency.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Lundbeck demonstrates a defined governance process to ensure alignment of its climate lobbying activities with its overall climate change strategy. The evidence specifies that "all communication with policy makers, authorities, trade associations and participation in other networks is coordinated and agreed between the Executive Vice President of Product Development & Supply (C-Suite Officer), the Corporate HSE department, Corporate Compliance & Sustainability and the Corporate Communication department." This indicates a clear structure for oversight and coordination of lobbying activities. Furthermore, the Corporate HSE department is responsible for "developing and managing Lundbeck's Climate strategy and for the follow up on all Lundbeck's climate initiatives and targets," ensuring alignment between climate strategy and lobbying efforts. The evidence also highlights that "preparation of input to upcoming legislation, participation in networks or climate seminars is performed by managers and employees from the Corporate HSE department," reinforcing the monitoring and management of lobbying activities. Additionally, the involvement of senior leadership, such as the CEO and Executive Vice President, in key decisions and external communications further underscores accountability and oversight. This indicates strong governance with defined processes, responsible parties, and alignment mechanisms for both direct and indirect lobbying activities.	3