Klepierre SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Klépierre provides a high level of transparency around its climate-policy lobbying. It names multiple, clearly identifiable initiatives it has worked on, including the E+C- Construction Label linked to France’s future environmental building regulation, the French Tertiary Decree, BREEAM In-Use version 6, and its response to the public consultation on the update of the European Directive on corporate extra-financial reporting. The company also explains in detail how it tries to influence these files: it “responded to the public consultation for the next update of the European Directive on corporate extra-financial reporting,” participates in “preparatory work” and “professional consultations” on building standards, sits in ECSP working groups that report to the association’s Executive Board, and engages investors and non-financial rating agencies to adjust carbon-related assessment criteria. These disclosures identify specific targets such as French regulators, European-level policymakers, EPRA, CNCC and ECSP, demonstrating clarity on both direct and association-based channels. On intended outcomes, Klépierre states that it seeks to harmonise extra-financial and climate-risk reporting across Europe, help shape and pilot future French environmental building rules via the E+C- label, and influence rating-agency questionnaires to better reflect carbon impacts, although it does not always quantify the exact amendments it supports. Overall, the company offers robust insight into the policies it lobbies, the mechanisms it uses and the changes it is pursuing.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Klépierre discloses some basic elements of lobbying governance but provides little detail on how these mechanisms ensure climate-lobbying alignment. The company notes that "The Anti-corruption Code of Conduct sets out the Group’s expectations regarding… lobbying activities" and states that "An Ethics and Compliance Committee has been set up to oversee the proper implementation of the compliance system and to rule on specific cases," indicating that lobbying falls within a wider compliance framework overseen by a named committee. In addition, the firm confirms a Paris-aligned intent, answering "Yes" to whether it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement." However, the disclosures do not explain how lobbying activities are monitored against this commitment, give no description of processes for reviewing direct or trade-association advocacy, and do not specify any regular assessments, corrective actions, or public reporting of alignment. We found no evidence of a dedicated climate-lobbying review, no identification of responsible individuals beyond the general compliance committee, and no discussion of how the company engages with or exits misaligned associations. This limited information signals some oversight of lobbying within the broader compliance system but does not amount to a detailed governance framework for ensuring that lobbying—direct or indirect—aligns with the company’s climate goals.	1