Holcim AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Holcim discloses a detailed, multi-layered governance framework that actively monitors and aligns both its direct and indirect climate-related lobbying with its 1.5 C strategy. The company states that its advocacy is led by Group Public Affairs, supported by Group Sustainability and regional experts, while the Chief Executive Officer and the Chief Sustainability and Innovation Officer of Holcim have the overall responsibility for the Policy; oversight and performance reviews are carried out by the Boards Health, Safety and Sustainability Committee (HSSC). Updates on lobbying are regularly presented to our main governing bodies, Board of Directors and the Executive Committee, demonstrating clear senior oversight. A dedicated Responsible Lobbying Directive sets conduct rules and, critically, Holcim publishes a standalone Climate Policy Engagement Report and Trade Association Climate Review, providing a publicly available audit that conduct[s] an annual trade association review focused onsupport for the Paris Agreements climate ambition and other climate-policy criteria; the company confirms that it commit[s] to publish a biannual review of the positions of the main trade organizations. The review has tangible consequences: In 2021, following a careful reviewHolcim decided to leave an industry organization due to misalignments on climate positions, and it notes that after latest assessments two are no longer associated with Holcim. For direct lobbying, the Public Affairs function ensures alignment on climate policy positions in all parts of the company by sharingposition papers and requiring validation by internal experts. Holcim pledges that should major divergences in positions appear, Holcim will dissociate itself from the trade associationor, in extreme cases, renounce its mandates, evidencing an enforcement mechanism. Collectively, these disclosurespublic audit, defined processes, named oversight bodies, and demonstrated corrective actionindicate a comprehensive governance system for climate lobbying; the company does not disclose granular board voting procedures, but the available information nonetheless signals strong, transparent and regularly reviewed controls over both direct and trade-association advocacy activities. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Holcim discloses a detailed, multi-layered governance framework that actively monitors and aligns both its direct and indirect climate-related lobbying with its 1.5 C strategy. The company states that its advocacy is led by Group Public Affairs, supported by Group Sustainability and regional experts, while the Chief Executive Officer and the Chief Sustainability and Innovation Officer of Holcim have the overall responsibility for the Policy; oversight and performance reviews are carried out by the Boards Health, Safety and Sustainability Committee (HSSC). Updates on lobbying are regularly presented to our main governing bodies, Board of Directors and the Executive Committee, demonstrating clear senior oversight. A dedicated Responsible Lobbying Directive sets conduct rules and, critically, Holcim publishes a standalone Climate Policy Engagement Report and Trade Association Climate Review, providing a publicly available audit that conduct[s] an annual trade association review focused onsupport for the Paris Agreements climate ambition and other climate-policy criteria; the company confirms that it commit[s] to publish a biannual review of the positions of the main trade organizations. The review has tangible consequences: In 2021, following a careful reviewHolcim decided to leave an industry organization due to misalignments on climate positions, and it notes that after latest assessments two are no longer associated with Holcim. For direct lobbying, the Public Affairs function ensures alignment on climate policy positions in all parts of the company by sharingposition papers and requiring validation by internal experts. Holcim pledges that should major divergences in positions appear, Holcim will dissociate itself from the trade associationor, in extreme cases, renounce its mandates, evidencing an enforcement mechanism. Collectively, these disclosurespublic audit, defined processes, named oversight bodies, and demonstrated corrective actionindicate a comprehensive governance system for climate lobbying; the company does not disclose granular board voting procedures, but the available information nonetheless signals strong, transparent and regularly reviewed controls over both direct and trade-association advocacy activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Holcim AG provides an extensive and detailed picture of its climate-policy advocacy. It names a wide range of concrete measures it seeks to influence, including the EU Emissions Trading System, the “Fit for 55” package, the “Carbon Border Adjustment Mechanism (CBAM),” the EU Industrial Carbon Management Strategy, the Net-Zero Industry Act, revisions to the Construction Products Regulation, the U.S. Inflation Reduction Act and sector-specific files such as “Renewable Fuels of Non-Biological Origin (RFNBOs)” and the EU CCUS Strategy. The company also explains how and to whom it lobbies. It describes “response to consultations”, “bilateral engagement with EU and national policymakers including letters sent to commissioners and MEPs”, public panel discussions at COP and Climate Week events, and sustained work through trade bodies such as Cembureau and the Global Cement and Concrete Association. It further identifies its targets as “representatives of the EU institutions”, “members of Parliament, regional and local authorities”, and officials met “bilaterally in our markets,” and lists formal registrations such as the EU Transparency Register, giving clear visibility of both direct and indirect channels. Finally, Holcim is explicit about the policy changes it wants. It calls for the “swift implementation of the Carbon Border Adjustment Mechanism (CBAM)” so that “non-EU importers bear the same CO2 costs as EU domestic producers”, urges deployment of “Carbon Contracts for Difference (CCFDs) at EU and national level” to de-risk low-carbon projects, seeks “integration of carbon performance in building standards and codes” on a life-cycle, material-neutral basis, and supports extensions for the use of captured CO₂ in synthetic fuels beyond 2041. It also advocates that carbon pricing frameworks be dynamic and that public procurement embed low-carbon and circular products. These concrete, measurable objectives make the purpose of its lobbying unmistakeable. By naming specific policies, detailing its lobbying channels and counterparts, and spelling out the outcomes it is pursuing, Holcim demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	A