Unibail-Rodamco-Westfield

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Unibail-Rodamco-Westfield provides a thorough and well-structured picture of its climate-policy advocacy. It names multiple, clearly identifiable policies on which it has intervened, including France’s building-energy law “Loi Elan,” the European “Non-Financial Reporting Directive (NFRD)” and its upgrade to the “Corporate Sustainability Reporting Directive (CSRD),” the experimental “E+C-” low-carbon building label, and the French energy regulation “RE2020,” as well as its work on adapting the BBCA low-carbon construction scheme. The company also spells out how it lobbies and whom it targets: it works through industry bodies such as FSIF and CNCC, participates in “working groups of AFEP” during EU consultations, submits data and case studies (e.g., the Sisters Towers project for the E+C- trial), and joins public consultations led by ADEME and other French and EU authorities, explicitly directing these efforts at the French government and the European Commission to influence implementing decrees and directive revisions. Finally, it is explicit about the concrete results it seeks—“make sure the transcription of ‘Loi Elan’ into application decrees can be understood and applied on the field,” “strengthen the bridge between the French greenhouse gas emissions report (BEGES) and the declaration of extra-financial performance (DPEF),” simplify and harmonise non-financial reporting requirements, inform RE2020 carbon thresholds, and refine the E+C- methodology for high-rise buildings—showing clearly articulated objectives rather than general aspirations. Taken together, these disclosures demonstrate a comprehensive level of transparency across the policies addressed, the mechanisms employed, and the outcomes pursued.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Unibail-Rodamco-Westfield has established a moderate governance process to ensure its policy engagement aligns with its climate objectives, primarily in its indirect lobbying through trade associations, although it does not disclose oversight for direct lobbying or name a responsible individual or body. The company explains that its “process is to habilitate people to represent the Group’s position on the topics at stake,” ensuring that “representation activities are carried only by habilitated people who have knowledge of the Group strategy on climate change and will not engage the Group on contradictory positions with its objectives.” It further notes a “strict process for managing authority and delegations ensuring that the right people from the right teams inform the right public policies, in line with the Group’s positions,” formalized in its Code of Ethics, which specifies that “each employee, manager and director must not commit the company beyond the extent of powers and delegations entrusted to him or her.” The company also confirms a public commitment to conduct its engagement activities in line with the goals of the Paris Agreement. However, the company does not disclose any process for reviewing or monitoring its direct lobbying activities nor does it identify a specific individual or formal body responsible for overseeing its climate-related lobbying alignment.	2