Puma SE – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	PUMA discloses a defined process to keep its lobbying in line with its climate strategy, noting that "the review procedure primarily involves PUMA's Senior Head of Corporate Sustainability that works in close cooperation with PUMAs Chief Sourcing Officer, Corporate Communications and Investor Relations departments to make sure that the activities which may influence policy are consistent with PUMA's overall strategy" and that any inconsistencies are escalated so that "a decision would be made by the members of the executive sustainability committee." The company identifies both direct and indirect channels, stating that the Senior Head "serves as one main contact for the most important trade associations" and that "PUMA messaging on sustainability related aspects is channeled through the Sustainability Department, to ensure that no conflicting messages are given," indicating an internal check on trade-association lobbying. Named oversight is clear: "Besides the oversight of the CEO, PUMA's Chief Sourcing Officer (CSO) who is a member of the Management Board, oversees all sustainability-related topics at PUMA including climate change on the board-level," complemented by "a sustainability committee on supervisory board level." These disclosures show concrete governance mechanisms, regular sign-off, and board-level accountability, which indicates stronger governance than a mere policy statement. However, the company does not disclose a stand-alone, publicly available lobbying-alignment audit. While it discloses its alignment with the Puerto Rico Manufacturers' Association and International Air Transport Association, it does it describe specific actions taken to challenge, correct or exit associations with misaligned climate positions; it only notes that alignment is sought by controlling communications. View Sources	C

Overall Assessment

Analysis

Score

Moderate

PUMA discloses a defined process to keep its lobbying in line with its climate strategy, noting that "the review procedure primarily involves PUMA's Senior Head of Corporate Sustainability that works in close cooperation with PUMAs Chief Sourcing Officer, Corporate Communications and Investor Relations departments to make sure that the activities which may influence policy are consistent with PUMA's overall strategy" and that any inconsistencies are escalated so that "a decision would be made by the members of the executive sustainability committee." The company identifies both direct and indirect channels, stating that the Senior Head "serves as one main contact for the most important trade associations" and that "PUMA messaging on sustainability related aspects is channeled through the Sustainability Department, to ensure that no conflicting messages are given," indicating an internal check on trade-association lobbying. Named oversight is clear: "Besides the oversight of the CEO, PUMA's Chief Sourcing Officer (CSO) who is a member of the Management Board, oversees all sustainability-related topics at PUMA including climate change on the board-level," complemented by "a sustainability committee on supervisory board level." These disclosures show concrete governance mechanisms, regular sign-off, and board-level accountability, which indicates stronger governance than a mere policy statement. However, the company does not disclose a stand-alone, publicly available lobbying-alignment audit. While it discloses its alignment with the Puerto Rico Manufacturers' Association and International Air Transport Association, it does it describe specific actions taken to challenge, correct or exit associations with misaligned climate positions; it only notes that alignment is sought by controlling communications.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	PUMA SE provides extensive, concrete information on every aspect of its climate-policy advocacy. It identifies a range of specific public measures it engages on, including the EU Taxonomy, the proposed Ecodesign for Sustainable Products Regulation, and encouragement of a legislative framework for direct power purchase agreements in Vietnam, as well as broader elements of the EU Green Deal and renewable-energy rules in key sourcing markets. The company is equally clear about how and where it tries to influence these policies: it submits comments and position papers through the Policy Hub, leads the Policy Working Group of the UN Fashion Industry Charter for Climate Action, sends formal letters to the Governments of Cambodia and Vietnam, takes part in country-specific task groups, and uses its Public Affairs staff and trade-association memberships such as FESI and Stiftung Klimawirtschaft to advocate with the European Commission and other national authorities. Finally, PUMA spells out the outcomes it is pursuing, such as inclusion of recycled polyester and cotton in the EU Taxonomy, acceptance of existing industry tools within the Ecodesign Regulation, the introduction of renewable-energy tariffs and PPAs for suppliers, political support for low- and zero-carbon fuels in logistics, and the phase-out of coal-fired boilers in its supply chain by 2025. Taken together, these disclosures demonstrate a comprehensive level of transparency about the policies lobbied, the mechanisms employed and the specific results the company seeks.	A