Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Moderate |
Comet Holding AG discloses a policy commitment that its "engagement activities" will be carried out "in line with the goals of the Paris Agreement" and states that it "is represented in the Sustainability Advisory Council of SEMI, ensuring that our climate strategy is consistent" with the association’s approach to climate protection. This indicates that the company has at least one mechanism for aligning its indirect lobbying through a key trade association with its own climate strategy. Furthermore, oversight of sustainability-related matters, including climate, is anchored at the top level: "The Board of Directors oversees and approves the sustainability strategy, including climate-related issues" and is "informed quarterly about the status of strategy implementation," though the disclosure does not explicitly tie this oversight to lobbying activities. While these statements demonstrate both a formal policy commitment and some evidence of an alignment process for external engagement, the company does not disclose a dedicated procedure for monitoring or reviewing lobbying positions, gives no detail on how direct lobbying is managed, and does not name an individual or committee that specifically oversees climate-lobbying alignment. Accordingly, the governance appears moderately developed but lacks the comprehensive monitoring, trade-association review, and explicit accountability mechanisms that would indicate strong governance.
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