Air France-KLM

Lobbying Governance

AI Extracted Evidence Snippet Source

Sustainable Development governance is ensured by the management bodies at the highest level of the Group. The Board of Directors and Executive Committees ensure that sustainability topics are given high priority and the sustainability teams report frequently to the most senior levels of management.

They make sure that sustainability decisions are taken at the right level within all the relevant entities:

- the Board of Directors approves the strategic orientations and monitors their implementation;

- within the Board of Directors, the Sustainable Development and Compliance Committee, established in 2018, assists in reviewing the risks and policies, by issuing recommendations and ensuring that issues linked to sustainable development are taken into account when defining the Group's strategy. In particular, twice a year, the Sustainable Development and Compliance Committee reviews the risks linked to climate change and the remedial measures in place. The minutes of the discussions and, as necessary, the recommendations arising from meetings of the Sustainable Development and Compliance Committee are presented to the Board of Directors. Having taken into account the recommendations of the Sustainable Development and Compliance Committee, the Audit Committee approves the review of the main extra-financial risks on an annual basis;

- the Group Executive Committee determines the sustainable strategy and development policy. It reviews the sustainable development strategy and performance. The Group's Corporate Secretary is responsible for Compliance and the Group Executive Vice President, Human Resources and Sustainability is responsible for Sustainability;

- at Air France, the sustainable development policy is steered by the Vice-President in charge of sustainable development and new mobility. He is supported by the Air France Sustainable Development Committee, composed of members of the Air France Executive Committee, which guides and ensures the progress of Air France's sustainable development strategy and efforts.

https://www.airfranceklm.com/sites/default/files/2023-12/SNBC%20UK_V2_181223.pdf

Regarding climate, a Decarbonization Committee was created in 2021 given the importance of the matter. This Committee, chaired by the Group Sustainability Director, is composed of the majority of the members of the GEC, as well as the Financial and Sustainability Directors of the Group and the airlines. It is responsible for updating the decarbonization roadmap and reviewing and advancing the Group's decarbonization strategy and its implementation. In this context, the Decarbonization Committee makes recommendations to the GEC. Matters are then discussed and validated by the GEC, before a report is presented to the Sustainable Development and Compliance Committee and the Board of Directors. [...] In addition, since fiscal year 2024, the Audit Committee's tasks have been extended to monitoring matters relating to the preparation, control and publication of sustainability information and, in particular, the preparation of the sustainability statement (including, in particular, the preparation of the double materiality matrix and the identification of relevant IROs). In this context, joint meetings between the Audit Committee and the Sustainable Development and Compliance Committee are organized to review sustainability information prior to approval of the CSRD annual report by the Air France-KLM Board of Directors."
"###### 4.4.2 Political Engagement & Lobbying Activities, Economic & Social Value of Air Transportation (G1-5)

The table below shows the material impacts, risks, and opportunities identified for this section:

**Material impact** **Time horizon**
**(N: negative;** **Own Operations (OO) /** **Material Risks (R)** **(short, medium, long**

**Topic** **P: positive)** **Value Chain (VC)** **or Opportunities (O)** **term)**

**Political engagement** P: Positive contribution OO/VC O: Air France-KLM short/medium/long
**& lobbying activities,** to social welfare and lobbying activities
**economic & social** economic to promote
**value of air** development at both the importance of air
**transportation** local and global level, transport industry

through direct and could contribute to fair
indirect economic competition and level
activities and playing field to secure
employment AFKL market position
opportunities or seize business

opportunities

For more information regarding the double materiality analysis and the identification of material IROs, please refer to
section 4.1.4.1 "Process to identify and assess material impacts, risks and opportunities (IRO-1)".

###### Public affairs governance

The shareholders and board members of the Air FranceKLM Group (the Group) share the concern about climate
change and place the global imperative of the
environmental transition of air transport at the heart of its
strategy.

The Board of Directors determines the direction of the
company's business and oversees its implementation,
taking into account social and environmental
considerations. Within this framework, it approves the
Group's strategic orientations, including its social and
environmental policies.

Respecting the environmental trajectory and successfully
activating the levers for reducing the negative
externalities of air transport are in the Group's strategic
interest (see section 4.2.1.3.1 "Transition plan for climate
change mitigation (E1-1)"). As such, these objectives are
among the key priorities of the mandate given to those
responsible for the representation of interests.

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.

The Deputy to the General Secretary, the Director of
Public and International Affairs, oversees the
organization's institutional advocacy activities in a crossfunctional capacity, working closely with subject-matter
experts in areas such as sustainability, operations, finance,

and legal affairs. The Director ensures that advocacy
efforts directed at external authorities – local, national,
European, and international – align with the material
topics identified under the CSRD Directive.

The chain of responsibility within the Group and its
subsidiaries complies with high standards of corporate
governance and ethical rules governing the
representation of interests. To prevent any conflict of
interest, special care is taken when recruiting executives
from the civil service. The jobs held by these employees
are compatible with their former functions, without any
undermining of the independence and neutrality of
public services.

In addition, professional retraining is monitored in
accordance with the rules of the French High Authority
for Transparency in Public Life (HATVP) in the cases
provided for in Article 23 of the 2013-907 law on
transparency in public life, notably when recruitment
within the Group takes place before the end of a threeyear period following retraining.

**Number of Board members**
**with previous public service responsibilities**

Before the end of the 3-year period
following retraining

2

After the end of the 3-year period 5

###### Principles of action and transparency

As a company (i) listed on the stock exchange; (ii) with two
national governments as shareholders; (iii) with an
ambitious social and environmental responsibility policy;
and (iv) with strong, recognized brands, the Air FranceKLM Group's lobbying activities adhere to high standards
of ethics, quality of expertise, and transparency.

The Air France-KLM Group and its subsidiaries Air France
and KLM are registered with the French (Haute Autorité
_pour la transparence de la vie publique – HATVP), Dutch,_
and European authorities in charge of transparency in
public life (EU Transparency Register of the European
Commission / REG number Air France-KLM:
064616126640-05 / REG number KLM: 76441066192-30).
They comply with declaratory obligations in terms of
chain of responsibility, communication with public
officials, declaration of activities and resources allocated
to them, and affiliation with professional associations in
charge of representing sectoral interests.

As part of its ethical principles, the Air France-KLM Group
makes no direct or indirect financial contribution to any
political organization or movement:

The Air France-KLM Group and its subsidiaries do,
however, represent their interests through industry
professional associations. The associations of which the
Air France-KLM Group is a member, and whose specific
vocation is to develop expertise or to intervene in the
challenges of the environmental transition of air transport,
recognize the global challenge of climate change. They
are committed to aligning their positions and actions with
the Paris Agreement objective of keeping global warming
below 1.5 degrees Celsius.

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.

https://www.airfranceklm.com/sites/default/files/2025-04/2024_urd-ven_04032025.pdf

The Group's different strategic plans seek to respond to these risks, particularly via the restructuring of the point‑to‑point operations, the accelerated development of Transavia, air/rail inter-modality development, fleet evolution and modernization, and the development of partnerships in large high‑growth markets. In parallel, the Group is lobbying the authorities for a legal framework ensuring fair competition between carriers (see also section 1.2 "Strategy" and 1.3 "Activities in 2021"). [...] Air France – KLM is a member of the representative associations for the airline industry (IATA, ATAG, A4E, FNAM) which engage in lobbying activities directed at the relevant national, European and international authorities and bodies (ICAO, European Union, supervisory Ministries in France and the Netherlands) to promote effective solutions for the environment, and also to ensure that the measures which are put in place do not lead to any distortion in competition between the air transportation players. [...] To keep the effects of these regulations as much as possible within financially‑acceptable limits, the Group lobbies the national and European institutions, both directly and indirectly through the air transportation industry's professional associations (IATA, A4E), to obtain reasonable obligations which create no competitive distortions or major additional costs which could lead it either to increase its fares or decrease its margins. In this respect, Air France – KLM continues to lobby for the revision of Regulation (EC) No.261/2004 of February 11, 2004. [...] The Air France – KLM Group actively defends its positions with the French and Dutch governments, and the European institutions, both directly and through industry bodies such as the Airlines for Europe association (A4E) regarding changes to European and national regulations. The Air France – KLM Group is engaged in direct lobbying of the European Commission and the national authorities to ensure a reasonable and balanced allocation of traffic rights to non-European airlines. Coordination with like‑minded carriers on this topic takes place within the framework of the Airline Coordination Platform (ACP).

https://www.airfranceklm.com/sites/default/files/publications_en/document/airfranceklm_urd_2021_va_0.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]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. In our processes it is embedded that these teams voice external opinions only based on internal validated documents. On topics that are somewhat related to sustainability or climate change, internal validation can only take place when the statements/position papers are approved by the sustainability department(s), which is the owner of our overall sustainability/climate change strategy. By following this governance/ decision making model, we ensure that external activities are consistent in line with our overall climate change strategy.

CDP Questionnaire Response 2022