OVH Groupe SAS

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	OVHcloud provides a solid level of transparency on its climate-related lobbying. It identifies several concrete policy frameworks it engages on, notably the European Green Deal, the EU Code of Conduct for Energy Efficiency in Data Centres and the industry-led Climate Neutral Data Centre Pact that is “the industry’s contribution to the European Green Deal,” indicating clear alignment with specific European climate initiatives. The company also outlines how it exerts influence: it shares positions “directly with public authorities,” organises visits to its data-centre facilities, participates in CISPE-led “workshops” with the European Commission and collaborates with trade associations such as EUDCA, Eco (Germany) and EuroCloud France. While the European Commission is explicitly named as a policymaking target, other public-authority targets are described more generally. OVHcloud is most detailed about the outcomes it seeks. Through the Climate Neutral Data Centre Pact it advocates for “Climate Neutrality for the cloud infrastructure industry by 2030,” including interim milestones such as having “power used … 100 % carbon free by 2030 (75 % minimum in 2025),” adopting ambitious PUE efficiency metrics, and promoting measures such as “recycling and reuse of heat produced by datacenters” and ensuring the “reuse, repair or recycle of all server equipment.” These quantified, time-bound objectives clearly convey the policy changes the company is lobbying for and why. Overall, the disclosures give a strong, though not exhaustive, picture of OVHcloud’s climate-policy lobbying activities, mechanisms and desired outcomes.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	OVH Groupe SAS discloses limited information about its lobbying governance processes. The company mentions that it "strives to be as transparent as possible in its dealings with public authorities" and complies with relevant laws and regulations. Oversight of compliance matters is attributed to "Senior Management and the Group's Board of Directors and Audit Committee," while operational compliance is managed by an in-house team under the responsibility of the "Legal Officer in charge of Ethics and Compliance." Additionally, "fortnightly reviews are organised with a member of the Group Executive Committee." However, the disclosure does not provide specific details about how lobbying activities, particularly climate-related lobbying, are monitored, aligned, or managed. There is no evidence of a defined process for ensuring alignment of lobbying activities with climate goals, nor is there mention of actions taken to address alignment with trade associations or other indirect lobbying channels. The governance framework lacks clarity on mechanisms for monitoring or enforcing lobbying alignment, particularly in the context of climate-related issues.	1