Air France-KLM – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Air France-KLM discloses a structured governance framework that links climate policy oversight with its lobbying activities, covering both its own advocacy and that undertaken through industry bodies. The company assigns clear responsibility, stating that “The General Secretary of the Board of Directors is responsible for implementing the company's environmental policy through institutional positioning and both direct and indirect advocacy actions,” while “the Director of Public and International Affairs… ensures that advocacy efforts… align with the material topics identified under the CSRD Directive.” A formal internal control step requires that “these teams voice external opinions only based on internal validated documents” and that, for climate-related topics, “statements/position papers are approved by the sustainability department(s)… the owner of our overall sustainability/climate change strategy,” demonstrating an explicit process to test lobbying positions against the company’s climate strategy before they are expressed externally. The disclosure also addresses indirect lobbying, explaining that membership associations “are committed to aligning their positions and actions with the Paris Agreement objective of keeping global warming below 1.5 degrees Celsius” and that “through its contribution to working groups and the collegial validation of positions taken within its organizations, the Air France-KLM Group ensures that the interests defended are aligned with its own strategic objectives in environmental matters.” Oversight escalates to the Board, which “determines the direction of the company's business and oversees its implementation, taking into account social and environmental considerations,” and climate matters are further reviewed by the Sustainable Development and Compliance Committee and the Decarbonization Committee. While this indicates strong governance—named accountable individuals, a pre-approval mechanism for both direct and association-based lobbying, and regular Board-level review—the company does not disclose a publicly available lobbying-alignment audit nor specific criteria for challenging or exiting misaligned trade associations, so the transparency of ongoing monitoring could be expanded. View Sources	B

Overall Assessment

Analysis

Score

Strong

Air France-KLM discloses a structured governance framework that links climate policy oversight with its lobbying activities, covering both its own advocacy and that undertaken through industry bodies. The company assigns clear responsibility, stating that “The General Secretary of the Board of Directors is responsible for implementing the company's environmental policy through institutional positioning and both direct and indirect advocacy actions,” while “the Director of Public and International Affairs… ensures that advocacy efforts… align with the material topics identified under the CSRD Directive.” A formal internal control step requires that “these teams voice external opinions only based on internal validated documents” and that, for climate-related topics, “statements/position papers are approved by the sustainability department(s)… the owner of our overall sustainability/climate change strategy,” demonstrating an explicit process to test lobbying positions against the company’s climate strategy before they are expressed externally. The disclosure also addresses indirect lobbying, explaining that membership associations “are committed to aligning their positions and actions with the Paris Agreement objective of keeping global warming below 1.5 degrees Celsius” and that “through its contribution to working groups and the collegial validation of positions taken within its organizations, the Air France-KLM Group ensures that the interests defended are aligned with its own strategic objectives in environmental matters.” Oversight escalates to the Board, which “determines the direction of the company's business and oversees its implementation, taking into account social and environmental considerations,” and climate matters are further reviewed by the Sustainable Development and Compliance Committee and the Decarbonization Committee. While this indicates strong governance—named accountable individuals, a pre-approval mechanism for both direct and association-based lobbying, and regular Board-level review—the company does not disclose a publicly available lobbying-alignment audit nor specific criteria for challenging or exiting misaligned trade associations, so the transparency of ongoing monitoring could be expanded.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Air France-KLM provides extensive and specific disclosure of its climate-related lobbying. It names numerous concrete policies it engages on, including “ReFuel EU Aviation,” the “revision of the EU ETS for Aviation,” the “Carbon Border Adjustment Mechanism,” CORSIA, national French provisions such as “art.142 mandatory offsetting for domestic flights” and “art.301 CO2 emission reduction trajectory,” as well as broader initiatives under the EU “Fit for 55” package and the “Single European Sky.” The company is equally explicit about its methods and audiences: it reports “advocacy work (through meetings and position papers) during inter-institutional negotiations,” direct engagement with “EU Member States and the European Union,” participation in ICAO assemblies, membership of European Commission working groups (e.g., the Biofuel Flightpath), dialogue with national air-transport authorities through FNAM and GIFAS, and leadership of the aviation roundtable within the Renewable and Low-Carbon Fuels Value Chain Industrial Alliance. Finally, Air France-KLM sets out the concrete results it seeks, such as a “harmonised EU SAF blending mandate,” “mechanisms to reduce the price gap between kerosene and SAF,” the “gradual phase-out of free EU ETS allowances” coupled with new “SAF Allowances,” alignment of CORSIA with the EU ETS to avoid double-counting, adoption of a global long-term carbon-reduction goal under ICAO, and implementation of Single European Sky reforms to cut flight emissions by 10 %. This level of detail across policies, mechanisms, and desired outcomes demonstrates highly transparent climate-policy lobbying.	A