Cementir Holding NV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Cementir Holding discloses a structured process that links its climate-related policy engagement to board-level oversight, indicating strong governance of both direct and indirect lobbying activities. The company states that "The Sustainability Committee is responsible for the coordination of all activities that influence policy" and that it "is responsible for the coordination of the participation of Cementir representatives in the various regional / global associations or public working groups," demonstrating a clear body with authority over lobbying. All engagement must be cleared in advance: "All the activities engaged by Cementir representatives must be previously agreed with the Sustainability Committee," and representatives "must engage in a way that reflects Cementir position, according to the instructions received by the Sustainability Committee," outlining a procedure to keep direct advocacy aligned with corporate climate strategy. The Committee also performs ongoing monitoring: it "is quarterly updated concerning the commitment of the mentioned associations or public working groups on public policy and concerning any relevant trend or upcoming legislation concerning climate change," enabling it to "evaluate the consistency of the activities performed by the associations and working group with Cementir Sustainability Strategy." For misalignment, the company commits that "In case, any major divergences ... should occur, Cementir will dissociate itself from the association ... In extreme situation, Cementir will resign," evidencing an active mechanism to address conflicts with trade associations. This process covers indirect lobbying through CEMBUREAU, GCCA and other bodies and direct engagement such as "leading the climate partnership for the Danish energy-intensive industry," all overseen by the same committee. While this indicates strong governance, the disclosures do not mention a formal public climate-lobbying alignment report, an external audit, or detailed criteria by which the Committee assesses alignment, so transparency is less comprehensive than best practice. View Sources	B

Overall Assessment

Analysis

Score

Strong

Cementir Holding discloses a structured process that links its climate-related policy engagement to board-level oversight, indicating strong governance of both direct and indirect lobbying activities. The company states that "The Sustainability Committee is responsible for the coordination of all activities that influence policy" and that it "is responsible for the coordination of the participation of Cementir representatives in the various regional / global associations or public working groups," demonstrating a clear body with authority over lobbying. All engagement must be cleared in advance: "All the activities engaged by Cementir representatives must be previously agreed with the Sustainability Committee," and representatives "must engage in a way that reflects Cementir position, according to the instructions received by the Sustainability Committee," outlining a procedure to keep direct advocacy aligned with corporate climate strategy. The Committee also performs ongoing monitoring: it "is quarterly updated concerning the commitment of the mentioned associations or public working groups on public policy and concerning any relevant trend or upcoming legislation concerning climate change," enabling it to "evaluate the consistency of the activities performed by the associations and working group with Cementir Sustainability Strategy." For misalignment, the company commits that "In case, any major divergences ... should occur, Cementir will dissociate itself from the association ... In extreme situation, Cementir will resign," evidencing an active mechanism to address conflicts with trade associations. This process covers indirect lobbying through CEMBUREAU, GCCA and other bodies and direct engagement such as "leading the climate partnership for the Danish energy-intensive industry," all overseen by the same committee. While this indicates strong governance, the disclosures do not mention a formal public climate-lobbying alignment report, an external audit, or detailed criteria by which the Committee assesses alignment, so transparency is less comprehensive than best practice.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Cementir Holding discloses a comprehensive picture of its climate-policy advocacy. It identifies the concrete measures it engages on, including the Danish Climate Law that targets a 70 % cut in national emissions by 2030, work on the revision of the EU Emissions Trading System for the “allocation of CO₂ quotas,” and provision of “feedback to the European Commission regarding the EU Taxonomy,” as well as support for forthcoming legislation on sustainable construction. The company is equally explicit about how and where it lobbies: the Managing Director of its subsidiary Aalborg Portland chairs Denmark’s climate partnership for energy-intensive industries, a role that involves supplying technical forecasts and recommendations directly to the Danish Government; it also channels positions through sector bodies such as Cembureau and the Global Cement and Concrete Association and participates in EU working groups developing ETS reform proposals. Finally, Cementir sets out the outcomes it seeks—helping Denmark achieve a 70 % emissions cut and climate neutrality by 2050, securing policy, research, innovation and subsidy frameworks that enable CO₂ reductions of 1.6 million tonnes at its Aalborg plant by 2030, and shaping ETS quota-allocation rules and sustainable-construction standards to accelerate decarbonisation of the cement sector—thereby making its policy objectives, direction of influence, and underlying rationale transparent.	A