LANXESS AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	LANXESS AG provides a highly detailed picture of its climate-policy lobbying. It names several identifiable pieces of legislation it seeks to influence, including the planned amendment to the EU Emissions Trading Directive covering “ETS II from 2027” and the inclusion of municipal waste incineration in “ETS I from 2028,” the German reform of electricity-grid charges, the CHP support regulation and Renewable Energy Act in Germany, as well as the update of European and national energy-efficiency legislation. The company also explains precisely how it intervenes: it holds a seat in the “Working Group Emission Trading” of the German Ministry for the Environment, chairs the VCI committee on climate protection and emissions trading, makes presentations to the North Rhine-Westphalia Ministry of Economy, and partners with bodies such as the North Rhine-Westphalia Ministry of Economics, the Cologne district government and EU policymakers, demonstrating both direct and association-based mechanisms targeted at specific authorities. LANXESS is equally explicit about what it wants to achieve, calling on the German government to “fundamentally reconsider the CO2 pricing of hazardous special waste,” seeking “generous transition periods” in the reform of grid fees, pushing for the “proper allocation of certificates for heat supply in industry,” and advocating to “allow for joint CHP projects by accepting financial support for industrial CHP” and to “overcome conflicts with exemption rules for renewable fees for self-generated electric power.” By setting out multiple concrete policy goals, the channels it uses, and the exact laws under debate, the company demonstrates comprehensive transparency on its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	LANXESS AG has established a structured governance process for its climate-related political advocacy through a dedicated steering committee. "LANXESS implemented a process to discuss, evaluate and assess its political activities on energy supply, energy efficiency and climate change with respect to LANXESS overall climate change strategy in a steering committee, the Climate and Energy Sub-Committee," which "includes members from all internally relevant stakeholder groups, such as the corporate development group, the purchasing department, the investor relations group, the corporate communications group as well as the largest and most energy intensive business units." The committee "is led by a board member and is part of the LANXESS Sustainability Committee," and ensures that any "new developments...are communicated to the Climate and Energy Sub-Committee who drive the response activities." However, we found no evidence of a parallel mechanism for aligning indirect lobbying via trade associations or industry bodies, nor does the company publish a dedicated audit or report explicitly evaluating the alignment of its lobbying activities with its climate commitments.	2