H Lundbeck A/S – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Lundbeck discloses a structured process for ensuring that its external policy engagement is consistent with its climate strategy by embedding it in the company’s ISO-certified HSE management system: "It is described in Lundbeck's HSE management system how internal and external communication is coordinated in the company." The procedure covers contacts with “policy makers, authorities, trade associations and participation in other networks” and requires that all such engagement be “coordinated and agreed between the Executive Vice President of Product Development & Supply, the Corporate HSE department, Corporate Compliance & Sustainability and the Corporate Communication department,” demonstrating both a clear chain of approval and the involvement of senior executives who also own the climate strategy. The company emphasises that “it is the same managers and employees that are responsible for the climate strategy, that participate in the network activities and the commenting on new legislation. This ensures consistent communication about our climate strategy,” which indicates an internal mechanism to align direct lobbying inputs with its climate ambitions. Oversight is further reinforced by the rule that “Only the Corporate Communication department can prepare press releases… but the content is always confirmed with Corporate Compliance & Sustainability, the Corporate HSE department and our Executive Vice President of Product Development & Supply,” and by a public commitment “to conduct [our] engagement activities in line with the goals of the Paris Agreement.” However, we found no evidence of a formal review of trade-association positions, no disclosure of any climate-lobbying audit or of actions taken to address misalignment, and no statement that the Board explicitly oversees lobbying alignment; the references to compliance with transparency registers (“Our EU lobbying activities are registered…,” “we are required to report quarterly to Congress”) concern legal reporting rather than an internal governance process. This indicates a moderate but not comprehensive governance framework focused mainly on coordinated direct engagement, with limited disclosure on how indirect lobbying through associations is monitored or corrected. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Lundbeck discloses a structured process for ensuring that its external policy engagement is consistent with its climate strategy by embedding it in the company’s ISO-certified HSE management system: "It is described in Lundbeck's HSE management system how internal and external communication is coordinated in the company." The procedure covers contacts with “policy makers, authorities, trade associations and participation in other networks” and requires that all such engagement be “coordinated and agreed between the Executive Vice President of Product Development & Supply, the Corporate HSE department, Corporate Compliance & Sustainability and the Corporate Communication department,” demonstrating both a clear chain of approval and the involvement of senior executives who also own the climate strategy. The company emphasises that “it is the same managers and employees that are responsible for the climate strategy, that participate in the network activities and the commenting on new legislation. This ensures consistent communication about our climate strategy,” which indicates an internal mechanism to align direct lobbying inputs with its climate ambitions. Oversight is further reinforced by the rule that “Only the Corporate Communication department can prepare press releases… but the content is always confirmed with Corporate Compliance & Sustainability, the Corporate HSE department and our Executive Vice President of Product Development & Supply,” and by a public commitment “to conduct [our] engagement activities in line with the goals of the Paris Agreement.” However, we found no evidence of a formal review of trade-association positions, no disclosure of any climate-lobbying audit or of actions taken to address misalignment, and no statement that the Board explicitly oversees lobbying alignment; the references to compliance with transparency registers (“Our EU lobbying activities are registered…,” “we are required to report quarterly to Congress”) concern legal reporting rather than an internal governance process. This indicates a moderate but not comprehensive governance framework focused mainly on coordinated direct engagement, with limited disclosure on how indirect lobbying through associations is monitored or corrected.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	H. Lundbeck A/S provides a highly transparent picture of its climate-policy lobbying. It lists several specific Danish measures it has engaged on, including the new national carbon-tax agreement, the “Energy Agreement of 29 June 2018 relating to surplus heat,” the “Agreement on increased utilization of surplus heat of 28 March 2019,” the “Climate agreement for energy and industry etc. of 22 June 2020,” and “Waste regulation no. 2159 of 09/12/2020,” as well as categorising these under carbon pricing, energy efficiency and waste-management policy. The company also spells out how it seeks to influence these files: it participates in the Danish Government’s Life Science & Biotech Climate Partnership, where it fills in questionnaires, attends seminars and workshops, joins consolidated meetings and submits comments on draft recommendations and sector road-maps, and it is registered in both the Danish lobby register and the EU Transparency Register while filing quarterly lobbying reports to the U.S. Congress. The targets of these efforts are clearly named, most notably the Danish Government and relevant ministers. Finally, Lundbeck is explicit about the results it wants, backing “a high CO₂ tax price signal of DKK 1,000/tCO₂,” calling for “remov[ing] the excess heat charge and adjust[ing] the electric-heating tax,” supporting electrification and a shift away from gas, and recommending regulatory changes to “create a better and clearer framework for recycling of waste” and to ease classification of certain waste streams as by-products. By detailing the policies addressed, the channels used and the precise legislative outcomes it seeks, the company demonstrates comprehensive transparency on its climate-related lobbying activities.	A