Holcim AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Holcim AG demonstrates a comprehensive level of transparency in disclosing its climate lobbying activities. The company explicitly identifies a wide range of specific climate policies it has engaged with, including the "EU ETS," "Carbon Border Adjustment Mechanism (CBAM)," "Renewable Fuels of Non-Biological Origins (RFNBOs)," "Recycled Carbon Fuels (RCFs)," and the "EU Strategy on Carbon Capture Usage and Storage (CCUS)." It also highlights its involvement in the "Fit for 55 Package" and the "Construction Products Regulation (CPR)," providing detailed context about these policies and their implications. Holcim provides detailed information about its lobbying mechanisms, such as "response to consultations," "bilateral engagement with EU and national policymakers including letters sent to commissioners and MEPs," and "engagement on the basis of position papers." It identifies specific targets of its lobbying efforts, including "EU and national policymakers," "commissioners," "MEPs," and the "EU's Technical Expert Group on taxonomy." Additionally, it engages globally through platforms like the "Carbon Pricing Leadership Coalition" and the "CEO Climate Dialogue." The company is equally transparent about the outcomes it seeks, such as advocating for "an early and swifter adoption" of the CBAM initiative, ensuring "effective CO2 cost equalization," and supporting "carbon-neutrality in construction" and advanced technologies like "Carbon Capture Utilization and Storage (CCUS)." Holcim also emphasizes the importance of "material-neutrality, life-cycle performance, and full value-chain mobilisation" in building standards and codes. This level of detail and clarity illustrates Holcim's comprehensive approach to disclosing its climate lobbying efforts and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Holcim demonstrates a defined governance process to ensure alignment of its climate lobbying activities, particularly through trade associations. The company has "assessed its memberships in its main trade organizations around the world" to ensure alignment with its climate policy positions. This assessment involved analyzing memberships based on financial contributions and geographical footprint, covering "c. 80% of the total amount that the Group paid to trade organizations in 2020." The review process was "led by the corporate public affairs team" and included an analysis of "the organizations' public positions, on their website, media releases, publications and social media." Additionally, Holcim sent a questionnaire to the organizations to gather further information and engaged in discussions with local public affairs teams to ensure alignment. The analysis was "reviewed with the Group's sustainability and stakeholder engagement team," indicating oversight by responsible parties. Holcim also outlines a proactive approach to addressing "major divergences in positions," stating that it will "work proactively with the organization in question to find alignment" or dissociate itself if alignment cannot be achieved. This indicates strong governance with clear monitoring mechanisms and accountability structures in place.	3