Air France-KLM

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Air France-KLM has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names specific climate policies it has engaged with, such as the "Fit for 55" package, "CORSIA," the "ReFuelEU Regulation," and the "Revision of the EU ETS for Aviation." It also references its contributions to the "Single European Sky (SES)" legislative package and the "Net-Zero Industry Act," providing clear identification of the policies engaged with and their alignment with its decarbonization goals. Air France-KLM provides detailed information about its lobbying mechanisms, including "advocacy work (through meetings and position papers)" during "inter-institutional negotiations," direct engagement with national and international policymakers, and participation in programs such as SESAR and ACARE. The company identifies its lobbying targets, such as the European Commission, ICAO, EU Member States, and national air transport authorities, demonstrating clarity in both the methods and the specific policymaking bodies engaged. Furthermore, Air France-KLM has been transparent about the specific policy outcomes it seeks to achieve, such as advocating for "a harmonised EU SAF blending mandate," "a strict SAF definition," and mechanisms to "reduce the price gap between kerosene and SAF." It also supports the revision of the EU ETS to "ensure a gradual phase-out of free EU ETS allowances" and "incentivize the uptake of SAF through SAF Allowances." Additionally, the company aims to achieve net zero emissions by 2050, supports smarter ICW Regulation, and calls for harmonization of reporting frameworks to align EU and international standards. These disclosures clearly outline the desired legislative changes and measurable targets Air France-KLM is lobbying for, illustrating its comprehensive approach to climate lobbying transparency.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Air France-KLM demonstrates a strong governance process for ensuring alignment of its climate lobbying activities with its climate change strategy. The evidence highlights that "engagement with policy makers and indirect engagement with trade associations is the official responsibility of the public affairs teams of the AFKL group, AirFrance and KLM," indicating that specific teams are tasked with overseeing lobbying activities. Furthermore, the governance model ensures that "external opinions [are voiced] only based on internal validated documents," with "internal validation" requiring approval from the sustainability department, which is responsible for the overall sustainability and climate change strategy. This process ensures that "external activities are consistent in line with our overall climate change strategy," demonstrating a clear and structured approach to monitoring and managing alignment. However, while this indicates strong governance with defined oversight and monitoring mechanisms, there is no evidence of a published lobbying audit or comprehensive review of lobbying alignment, which would further enhance transparency and accountability.	3