Electrolux AB – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Electrolux describes a structured process for keeping its policy engagement in line with its climate strategy, noting that Group Sustainability and Group External Affairs functions are responsible for policies and positions development related to sustainability matters, including the climate change area and that these positions are developed and agreed in a cross-regional team (Group External Affairs Committee GEAC) Final decisions are made by Group management. The company states that it involves all relevant stakeholders on a global level, through monthly and/or quarterly forums, to be updated on strategy and positions and that if inconsistencies occur the CEO has the ultimate power to override business sector decision, indicating an internal mechanism to monitor and correct misaligned lobbying. Oversight responsibility is clearly allocatedGroup Management and functional heads have the overall responsibility for our public policy, while the GEAC coordinates positions and other public affairs matters, and the CEO can intervene on material issuesshowing identifiable accountability. Public policy activities are said to be primarily conducted through industry organizations, which demonstrates the company covers indirect lobbying. However, other than confirming various EU lobbying positions that are aligned with the Internal Round-table of Household Appliance Manufacturer Association, its disclosure stops short of explaining how it tests those associations for climate-policy alignment or whether it engages, reforms, or exits where misalignment exists. There is also no published climate-lobbying audit or independent review. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Electrolux describes a structured process for keeping its policy engagement in line with its climate strategy, noting that Group Sustainability and Group External Affairs functions are responsible for policies and positions development related to sustainability matters, including the climate change area and that these positions are developed and agreed in a cross-regional team (Group External Affairs Committee GEAC) Final decisions are made by Group management. The company states that it involves all relevant stakeholders on a global level, through monthly and/or quarterly forums, to be updated on strategy and positions and that if inconsistencies occur the CEO has the ultimate power to override business sector decision, indicating an internal mechanism to monitor and correct misaligned lobbying. Oversight responsibility is clearly allocatedGroup Management and functional heads have the overall responsibility for our public policy, while the GEAC coordinates positions and other public affairs matters, and the CEO can intervene on material issuesshowing identifiable accountability. Public policy activities are said to be primarily conducted through industry organizations, which demonstrates the company covers indirect lobbying. However, other than confirming various EU lobbying positions that are aligned with the Internal Round-table of Household Appliance Manufacturer Association, its disclosure stops short of explaining how it tests those associations for climate-policy alignment or whether it engages, reforms, or exits where misalignment exists. There is also no published climate-lobbying audit or independent review.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Electrolux shows a moderate level of transparency around its climate-related lobbying. It names a wide range of concrete policy files it has engaged on, including the “Revision of the EU energy label and energy efficiency legislation (eco-design legislation),” forthcoming “EU legislation on circular economy and resource efficiency,” proposed “Changes to the CO2 trading scheme (ETS) and a Carbon Border Adjustment Mechanism (CBAM),” “Department of Energy (DOE) appliance standard rulemakings” in North America and “recycling program structuring in Brazil.” The company also explains how it lobbies, stating that public-policy activity is “primarily conducted through industry organizations, such as the European Appliance Industry Association (APPLIA) and the Association of Home Appliance Manufacturers in the United States and Canada (AHAM),” and that “each business area is responsible for engaging with their respective policy makers,” indicating both indirect association channels and direct corporate contacts with bodies such as the U.S. DOE and EU institutions. However, Electrolux is far less specific about what it is trying to achieve: it simply notes its support for initiatives like “EU legislation on circular economy and resource efficiency” and proposed revisions to the ETS and CBAM without detailing the concrete amendments, targets or timelines it is advocating. As a result, while the company provides solid detail on which policies it lobbies and the channels it uses, it offers only high-level statements on the outcomes it seeks, limiting the overall depth of its disclosure.	C