Roche Holding AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Roche Holding AG demonstrates a robust enterprise risk management framework, with “a system of controls which is continuously monitored by the Audit Committee, by the Corporate Governance and Sustainability Committee and by the Board of Directors” and a Corporate Governance and Sustainability Committee that “is responsible and accountable for governing sustainability at the Board level,” embedding climate-related risks into its overall risk processes. The company also outlines its approach to public policy engagement, noting “we are convinced that proactively and responsibly engaging with public policy stakeholders is a fundamental aspect of good public governance” and discloses its lobbying expenditures and association memberships, stating that “where appropriate, Roche discloses contributions to associations and political institutions publicly and signs up in transparency registers of public authorities.” However, we found no evidence of a specific policy or process for governing or aligning Roche’s direct or indirect lobbying activities with its climate objectives, nor any named individual or formal body tasked with reviewing lobbying alignment, and there is no disclosed mechanism for monitoring, sign-off or management of lobbying efforts against climate or sustainability goals. View Sources	E

Overall Assessment

Analysis

Score

None

Roche Holding AG demonstrates a robust enterprise risk management framework, with “a system of controls which is continuously monitored by the Audit Committee, by the Corporate Governance and Sustainability Committee and by the Board of Directors” and a Corporate Governance and Sustainability Committee that “is responsible and accountable for governing sustainability at the Board level,” embedding climate-related risks into its overall risk processes. The company also outlines its approach to public policy engagement, noting “we are convinced that proactively and responsibly engaging with public policy stakeholders is a fundamental aspect of good public governance” and discloses its lobbying expenditures and association memberships, stating that “where appropriate, Roche discloses contributions to associations and political institutions publicly and signs up in transparency registers of public authorities.” However, we found no evidence of a specific policy or process for governing or aligning Roche’s direct or indirect lobbying activities with its climate objectives, nor any named individual or formal body tasked with reviewing lobbying alignment, and there is no disclosed mechanism for monitoring, sign-off or management of lobbying efforts against climate or sustainability goals.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	The company offers a moderate level of transparency on climate-policy lobbying. It names two identifiable climate-related processes—the Australian “National Health and Climate Strategy consultation” and the 2023 “Regulatory Reform of Packaging” discussion paper—showing it does disclose some of the specific public-policy files it engages with. It also describes several channels through which it lobbies, stating that it engages “government officials, legislatures, and agencies,” files submissions to government consultations, works through trade associations such as IFPMA and EFPIA, and uses political action committees that interact with EU institutions like the European Parliament and Commission. These examples reveal both direct and indirect mechanisms as well as clear institutional targets, although most illustrations relate broadly to healthcare rather than climate. On the outcomes sought, the disclosure is limited: beyond a general ambition to “advocate public policies that support innovation and benefit … society,” the company does not articulate concrete climate-policy changes or quantitative objectives it wants governments to adopt, merely indicating a wish to help shape the nascent National Climate and Health Strategy. Overall, the company provides some useful detail on the policies addressed and the way it interacts with policymakers, but it stops short of specifying the precise climate outcomes it is pursuing.	C