Coca-Cola HBC AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Coca-Cola HBC AG demonstrates a comprehensive governance process for climate lobbying, ensuring alignment with its climate-related goals and the Paris Agreement. The company explicitly states that "all our direct or indirect advocacy is aligned with our commitment to achieve NetZero by 2040" and has mechanisms to monitor and review memberships in trade associations annually to ensure alignment with the Paris Agreement goals. The Chief Corporate Affairs and Sustainability Officer oversees this process, with actions such as "direct engagement with the trade association with clear timelines to address these differences," "public statements distancing the company from the misalignment," and "remedial actions such as leaving the trade association" being part of the compliance framework. Furthermore, the Social Responsibility Committee of the Board of Directors monitors progress against sustainability targets and reviews engagement activities to ensure alignment. The company also publishes detailed climate information in its Integrated Annual Report, validated by an independent assurance provider, which identifies and states any inconsistencies in engagement activities with its climate strategy. This governance structure, which includes oversight by the Chief CA&S Officer and the Board's Social Responsibility Committee, ensures robust monitoring and accountability for both direct and indirect lobbying activities, supported by a clear policy and detailed processes for alignment and corrective actions. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Coca-Cola HBC AG demonstrates a comprehensive governance process for climate lobbying, ensuring alignment with its climate-related goals and the Paris Agreement. The company explicitly states that "all our direct or indirect advocacy is aligned with our commitment to achieve NetZero by 2040" and has mechanisms to monitor and review memberships in trade associations annually to ensure alignment with the Paris Agreement goals. The Chief Corporate Affairs and Sustainability Officer oversees this process, with actions such as "direct engagement with the trade association with clear timelines to address these differences," "public statements distancing the company from the misalignment," and "remedial actions such as leaving the trade association" being part of the compliance framework. Furthermore, the Social Responsibility Committee of the Board of Directors monitors progress against sustainability targets and reviews engagement activities to ensure alignment. The company also publishes detailed climate information in its Integrated Annual Report, validated by an independent assurance provider, which identifies and states any inconsistencies in engagement activities with its climate strategy. This governance structure, which includes oversight by the Chief CA&S Officer and the Board's Social Responsibility Committee, ensures robust monitoring and accountability for both direct and indirect lobbying activities, supported by a clear policy and detailed processes for alignment and corrective actions.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Coca-Cola HBC AG provides a high level of transparency around its climate-related lobbying. It explicitly names the draft EU Packaging and Packaging Waste Regulation, national deposit-return legislation in Poland, and broader EU initiatives such as the EU Green Deal, the EU Code of Conduct for responsible business and marketing practices, and the EU Farm-to-Fork Strategy, showing exactly which policy files it seeks to influence. The company is equally clear about how it engages: it “engage[s] mainly through trade associations” such as UNESDA and EUROPEN, supplements this with “limited direct advocacy” via public-affairs agencies, submits position papers that are filed with the European Commission, European Parliament and Council, and participates in consultation meetings on specific regulations and deposit-return schemes. Finally, it sets out the concrete outcomes it is pursuing, backing the Packaging and Packaging Waste Regulation while calling for “environmental and economic impact assessments for reuse targets,” a “broad definition of reuse,” “average recycled content targets,” “fair access to recycling feedstock for beverage bottle producers,” and “enhanced minimum requirements for deposit return systems,” alongside its wider aim to “support a net zero Europe by 2050.” By disclosing the policies, the mechanisms and targets of engagement, and the detailed changes it seeks, the company demonstrates comprehensive transparency on its climate-policy lobbying activities.	A