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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Heidelberg Materials AG demonstrates a comprehensive level of transparency in disclosing its climate lobbying activities. The company explicitly identifies numerous specific climate policies it has engaged with, such as the EU Emissions Trading Scheme (EU ETS), the Carbon Border Adjustment Mechanism (CBAM), the Net-Zero Industry Act (NZIA), and the Renewable Energy Directive (REDIII). It also highlights its advocacy for policies like carbon pricing, renewable energy expansion, and circular economy measures, providing detailed context about its focus areas and geographical scope. Heidelberg Materials provides extensive details about its lobbying mechanisms and targets, including direct engagement with decision-makers such as representatives of the European Commission, Members of the European Parliament, and national parliament members. It also engages with think tanks, NGOs, and trade associations like CEMBUREAU and GCCA through personal meetings, public consultations, and participation in public events and hearings. Furthermore, the company discloses its participation in high-level events like COP27 and its registration in transparency registers, such as the EU Transparency Register and the German Bundestag Lobby Register. The company is equally transparent about the specific outcomes it seeks, such as advocating for higher carbon pricing, the inclusion of cement in the CBAM, the development of funding schemes for decarbonization technologies, and the establishment of green lead markets. It also emphasizes the importance of circular economy solutions, renewable energy policies, and infrastructure development for CCUS technologies. These disclosures collectively illustrate Heidelberg Materials' structured and transparent approach to climate lobbying, aligning its efforts with its climate transition plan and net-zero objectives.
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4
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Heidelberg Materials demonstrates a comprehensive governance process for climate lobbying alignment, supported by detailed disclosures in its "Climate Advocacy and Association Review 2023." The company has published an annual lobbying report that explicitly reviews its direct and indirect lobbying activities, including those conducted through trade associations. For example, the report states, "We are reviewing our engagement in national trade associations annually and pay special attention to key countries," and outlines a methodology for assessing trade associations' alignment with the Paris Agreement goals. This includes evaluating whether associations meet six defined criteria, such as advocating for carbon pricing and supporting advanced technologies like CCUS. The governance process is robust, with clear oversight structures and accountability measures. The Chief Sustainability Officer (CSO) and a board member are identified as responsible for overseeing the alignment of trade associations with the Paris Agreement, with quarterly reviews conducted to ensure compliance. The report specifies, "The alignment of trade associations with goals of the Paris Agreement is quarterly reviewed with the Chief Sustainability Officer (CSO) and the board member responsible for associations." Additionally, the company has established a "global function to provide continuous oversight over industry association advocacy," ensuring alignment with its climate positions. Heidelberg Materials also describes its proactive measures to address misalignment, stating, "If an association's position on a strategically important issue differs from ours, we will increase our engagement in the association's committees and signal our dissent to improve the alignment or to demand the association not take a position." The company further commits to publicly stating its disagreement and reviewing membership value if alignment cannot be achieved, emphasizing its commitment to responsible advocacy. The report includes a detailed review of 23 cement trade associations, categorizing their alignment with the Paris Agreement as "fully aligned," "partially misaligned," or "misaligned." It also highlights actions taken to improve alignment, such as encouraging the GCCA to roll out its Net Zero Accelerator Programme in various countries. This indicates a thorough and transparent approach to managing indirect lobbying activities. Overall, Heidelberg Materials has demonstrated a comprehensive governance process for climate lobbying, with clear policies, monitoring mechanisms, and accountability structures in place, supported by detailed disclosures in its annual review.
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4
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