Novartis AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Novartis describes its process for ensuring that “policy positions, targets and disclosures are aligned across Novartis through Executive Committee-level membership of the Environmental Sustainability Strategy Implementation Steering Committee, as well as via the Trust and Reputation Committee,” and commits that “quarterly meetings are scheduled to align with the Government Affairs and Public Affairs offices for the US and European Union.” It further clarifies that “the Novartis climate strategy and our commitment to become net zero by 2040 is used by our Communications and Engagement teams when they engage on climate related issues,” and that “if any misalignment was identified ... the Sustainability & ESG office would seek to restore consistency between our position and any external advocacy.” The company also affirms a public commitment “to conduct your engagement activities in line with the goals of the Paris Agreement.” Oversight of these processes is provided by formal bodies, including the Sustainability & ESG office and the Trust and Reputation Committee, chaired by the CEO. However, the company does not disclose a structured process for evaluating or modifying its trade association memberships or other indirect lobbying channels against its climate goals, indicating that indirect lobbying alignment mechanisms are not fully articulated. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Novartis describes its process for ensuring that “policy positions, targets and disclosures are aligned across Novartis through Executive Committee-level membership of the Environmental Sustainability Strategy Implementation Steering Committee, as well as via the Trust and Reputation Committee,” and commits that “quarterly meetings are scheduled to align with the Government Affairs and Public Affairs offices for the US and European Union.” It further clarifies that “the Novartis climate strategy and our commitment to become net zero by 2040 is used by our Communications and Engagement teams when they engage on climate related issues,” and that “if any misalignment was identified ... the Sustainability & ESG office would seek to restore consistency between our position and any external advocacy.” The company also affirms a public commitment “to conduct your engagement activities in line with the goals of the Paris Agreement.” Oversight of these processes is provided by formal bodies, including the Sustainability & ESG office and the Trust and Reputation Committee, chaired by the CEO. However, the company does not disclose a structured process for evaluating or modifying its trade association memberships or other indirect lobbying channels against its climate goals, indicating that indirect lobbying alignment mechanisms are not fully articulated.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Novartis provides comprehensive transparency around its climate-related lobbying activities. It explicitly identifies its engagement on specific climate legislation, naming the US Build Back Better Act, the Corporate Sustainability Due Diligence Directive in Europe, and the EU Emissions Trading System as core policy priorities. The company details its lobbying mechanisms, describing participation in webinars, public events and panels in partnership with organizations like WBCSD, Ceres and the Environmental League of Massachusetts; lawmaker education sessions; and private discussions in drafting communications to legislators—targeting policymakers connected to major legislative initiatives. Novartis also articulates clear outcomes sought, advocating for “removing regulatory barriers for mobilization of private capital for deep penetration of renewables and energy storage in existing grids globally,” enabling “use of power purchase agreements and other contractual and financial arrangements” to decarbonize energy systems, promoting enhanced Scope 3 reporting, support for market-based accounting, improved traceability systems, and supporting the development and expansion of the EU-ETS to make it more effective and practical.	A