Holcim AG

Lobbying Governance

AI Extracted Evidence Snippet Source

**_●_** **_Advocacy:_** To ensure that our direct and indirect advocacy through trade associations are aligned with the Paris Agreement, we commit to publish a regular review of our climate-related public positions at corporate level and for our main markets. We also commit to publish a biannual review of the positions of the main trade organizations we are a member of to verify that there are no major misalignments with the Group's positions on climate change. [...] ### Responsibility 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 Board's Health, Safety and Sustainability Committee (HSSC); Chief Executive Committees in countries where we operate take responsibility and are accountable for assessing and addressing local climate performance.

https://www.holcim.com/sites/holcim/files/2023-04/holcim_climate_policy.pdf

Holcim engages globally with Government, NGO, civil society and local stakeholders on the use of co-processing technology, which allows to simultaneously substitute fossil fuels with non-recyclable waste-derived fuels and to recycle the mineral contained in the fuel into our production processes. The use of this technology requires a well established regulatory framework on waste management, as is the case in jurisdictions such as Europe, India and many countries around the world. And, it needs adequate recognition as a desirable waste management alternative that responds to the waste management hierarchy. [...] Holcim engages both directly and indirectly with representatives of the EU institutions on what probably forms the most significant legislative package of the current European Commission. Holcim welcomes the 'Fit for 55' package released by the European Commission on 14th July. If elements of the package bring a risk element (increase carbon costs), this package is mostly about providing policy enablers that should in principle allow us to build the necessary business case to deploy low carbon technologies and solutions.

https://www.holcim.com/sites/holcim/files/documents/holcim_cdp_climate_change_response_2021.pdf

* Public affairs\n\n* Industry Associations Climate Policy Review\n* Climate Public Policy Positions\n* Responsible Lobbying and Advocacy Directive\n* Climate Policy Engagement Report 2024

https://www.holcim.com/sustainability/esg/esg-policies-documents-reports

**Ignoring page 0 with 1985+ vector graphics.**

--NEW-PAGE--

**Ignoring page 1 with 2171+ vector graphics.**

--NEW-PAGE--

**Ignoring page 2 with 1273+ vector graphics.**

--NEW-PAGE--

**Ignoring page 3 with 1848+ vector graphics.**

--NEW-PAGE--

**Ignoring page 4 with 1552+ vector graphics.**

--NEW-PAGE--

**Ignoring page 5 with 1883+ vector graphics.**

https://www.holcim.com/sites/holcim/files/documents/advocacy_faq_final.pdf

**Ignoring page 1 with 2097+ vector graphics.**

--NEW-PAGE--

**Ignoring page 2 with 1638+ vector graphics.**

--NEW-PAGE--

**Ignoring page 3 with 2597+ vector graphics.**

--NEW-PAGE--

**Ignoring page 4 with 1984+ vector graphics.**

--NEW-PAGE--

**Ignoring page 5 with 2423+ vector graphics.**

--NEW-PAGE--

**Ignoring page 6 with 1917+ vector graphics.**

https://www.holcim.com/sites/holcim/files/2023-05/holcim_public_policy-may-2023.pdf

Holcim advocates for climate policy positions that enable: **1. Carbon capture, utilization and storage (CCUS)** One decarbonization lever that is fundamental to the sector's transition is CCUS. The regulatory frameworks that are currently being developed will play fundamental roles in enabling the CCUS value chain to become the necessary engine of the low-carbon and circular transition. No single solution will be perfectly scalable everywhere as different environments present different conditions (e.g. technological, geological and legislative) that favor one solution or another. This requires a flexible yet unequivocal regulatory framework: - Recognizing carbon use as an integral part of the transition to net zero is a necessity, as is avoiding the design of restrictive regulatory frameworks that prevent the scale-up of industrial carbon capture projects. Policies under development (e.g. on synthetic fuels in the EU) cast serious doubts on the future of CO2 utilization from industrial sources, without any serious impact assessment. - A dynamic, accessible and competitive value chain for CO2 transport and storage. Europe must focus on securing accessible infrastructure for carbon capture, transport and storage. The current monopolistic environment threatens the viability of many projects that would otherwise be implemented before 2030 (and which require planning, permitting and financing now). [...] **Trade Associations Climate Review** Our commitment to climate-related reporting is transparent and rigorous and we take the same approach in our advocacy positions. Aligned with our net-zero pledge, Holcim is committed to ensuring that our direct and indirect lobbying through trade associations is aligned with the Paris Agreement and Holcim's positions outlined below. - Support for the Paris Agreement's climate targets and net-zero agenda - Support for the use of carbon-pricing mechanisms - Development of industry roadmap to net-zero by 2050 - Acknowledgement of the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations) - Support of need to introduce low-carbon products We selected the most significant organizations, ensuring a balanced geographical distribution and including global, regional and national organizations. The organizations were assessed by reviewing their public positions using their websites, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs teams. [...] Where any selected organizations has material misalignment or diverging views with Holcim's policy positions and cannot be considered to be part of the acceleration to net zero, we commit to dissociate ourself from the trade association and related activities or, in extreme cases, renounce our mandates within the organization and/or our membership. After our review, we pursued our work with all the organizations included in the scope to close the gaps and push for more alignment with our positions and commitments on climate policies. As a result, seven out of ten organizations that had not developed net-zero roadmaps three years ago, have now issued and published their roadmaps[1]. Two organizations that did not formally declare their support for the Paris Agreement have formalized their positions since. Holcim commits to continually assess the climate policy positions of our trade association and memberships on a periodic basis.

https://www.holcim.com/sites/holcim/files/2024-03/28022024-finance-holcim-fy-2023-report-en.pdf

* Public affairs\n\n* Industry Associations Climate Policy Review\n* Climate Public Policy Positions\n* Responsible Lobbying and Advocacy Directive\n* Climate Policy Engagement Report 2024

https://www.holcim.com/sustainability/esg/esg-policies-documents-reports

The HSSC advises the Board of Directors on all matters related to sustainable development. It reviews and approves the company's climate related plans and targets. The HSSC consists of five Board members. The Chairman of the Board of Directors (unless they are a member of the HSSC), the Vice Chairman, the Group CEO, the Group Chief Sustainability and Innovation Officer (CSIO), the Group General Counsel, the Group Head of Security and the Group Head of Health, Safety and Environment participate as invited guests. The HSSC meets at least quarterly. The HSSC supports and advises the Board of Directors on the development and promotion of a healthy and safe environment for employees and contractors, as well as on sustainable development and social responsibility. In 2022, the HSSC held four meetings. The average duration of the meetings was two hours. The president of the HSSC then reports to the Board on the conclusions of the meeting. In addition, as a member of the Executive Committee, the CSIO attends part of all Board meetings and presents the sustainability strategy at the Board strategy workshop.

https://www.holcim.com/sites/holcim/files/2024-02/cdp-climate-change-response-2023.pdf

Holcim advocates for climate policy positions that enable: **1. Carbon capture, utilization and storage (CCUS)** One decarbonization lever that is fundamental to the sector's transition is CCUS. The regulatory frameworks that are currently being developed will play fundamental roles in enabling the CCUS value chain to become the necessary engine of the low-carbon and circular transition. No single solution will be perfectly scalable everywhere as different environments present different conditions (e.g. technological, geological and legislative) that favor one solution or another. This requires a flexible yet unequivocal regulatory framework: - Recognizing carbon use as an integral part of the transition to net zero is a necessity, as is avoiding the design of restrictive regulatory frameworks that prevent the scale-up of industrial carbon capture projects. Policies under development (e.g. on synthetic fuels in the EU) cast serious doubts on the future of CO2 utilization from industrial sources, without any serious impact assessment. - A dynamic, accessible and competitive value chain for CO2 transport and storage. Europe must focus on securing accessible infrastructure for carbon capture, transport and storage. The current monopolistic environment threatens the viability of many projects that would otherwise be implemented before 2030 (and which require planning, permitting and financing now). [...] **Trade Associations Climate Review** Our commitment to climate-related reporting is transparent and rigorous and we take the same approach in our advocacy positions. Aligned with our net-zero pledge, Holcim is committed to ensuring that our direct and indirect lobbying through trade associations is aligned with the Paris Agreement and Holcim's positions outlined below. - Support for the Paris Agreement's climate targets and net-zero agenda - Support for the use of carbon-pricing mechanisms - Development of industry roadmap to net-zero by 2050 - Acknowledgement of the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations) - Support of need to introduce low-carbon products We selected the most significant organizations, ensuring a balanced geographical distribution and including global, regional and national organizations. The organizations were assessed by reviewing their public positions using their websites, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs teams. [...] We recognize that the journey to net zero requires radical collaboration across our entire value chain and with regulators, investors, NGOs, civil societies and employees. We are committed to working with these stakeholders and our trade associations to accelerate that journey. Where any selected organizations has material misalignment or diverging views with Holcim's policy positions and cannot be considered to be part of the acceleration to net zero, we commit to dissociate ourself from the trade association and related activities or, in extreme cases, renounce our mandates within the organization and/or our membership. After our review, we pursued our work with all the organizations included in the scope to close the gaps and push for more alignment with our positions and commitments on climate policies. As a result, seven out of ten organizations that had not developed net-zero roadmaps three years ago, have now issued and published their roadmaps[1]. Two organizations that did not formally declare their support for the Paris Agreement have formalized their positions since. Holcim commits to continually assess the climate policy positions of our trade association and memberships on a periodic basis. [...] Holcim's public policy positions and its climate advocacy activities are systematically underpinned by the Group SBTi's 1.5°C roadmap and associated targets, which are externally verified and fully aligned with the Paris Agreement. Review of the climate policy positions of trade associations and industry bodies entails a review of our own policy position and confirms their alignment to the Paris Agreement and net-zero agenda.

https://www.holcim.com/sites/holcim/files/2024-04/28022024-holcim-climate-report-2023.pdf

Holcim advocates for climate policy positions that enable: **1. Carbon capture, utilization and storage (CCUS)** One decarbonization lever that is fundamental to the sector's transition is CCUS. The regulatory frameworks that are currently being developed will play fundamental roles in enabling the CCUS value chain to become the necessary engine of the low-carbon and circular transition. No single solution will be perfectly scalable everywhere as different environments present different conditions (e.g. technological, geological and legislative) that favor one solution or another. This requires a flexible yet unequivocal regulatory framework: - Recognizing carbon use as an integral part of the transition to net zero is a necessity, as is avoiding the design of restrictive regulatory frameworks that prevent the scale-up of industrial carbon capture projects. Policies under development (e.g. on synthetic fuels in the EU) cast serious doubts on the future of CO2 utilization from industrial sources, without any serious impact assessment. - A dynamic, accessible and competitive value chain for CO2 transport and storage. Europe must focus on securing accessible infrastructure for carbon capture, transport and storage. The current monopolistic environment threatens the viability of many projects that would otherwise be implemented before 2030 (and which require planning, permitting and financing now). [...] **Trade Associations Climate Review** Our commitment to climate-related reporting is transparent and rigorous and we take the same approach in our advocacy positions. Aligned with our net-zero pledge, Holcim is committed to ensuring that our direct and indirect lobbying through trade associations is aligned with the Paris Agreement and Holcim's positions outlined below. - Support for the Paris Agreement's climate targets and net-zero agenda - Support for the use of carbon-pricing mechanisms - Development of industry roadmap to net-zero by 2050 - Acknowledgement of the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations) - Support of need to introduce low-carbon products We selected the most significant organizations, ensuring a balanced geographical distribution and including global, regional and national organizations. The organizations were assessed by reviewing their public positions using their websites, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs teams. [...] We recognize that the journey to net zero requires radical collaboration across our entire value chain and with regulators, investors, NGOs, civil societies and employees. We are committed to working with these stakeholders and our trade associations to accelerate that journey. Where any selected organizations has material misalignment or diverging views with Holcim's policy positions and cannot be considered to be part of the acceleration to net zero, we commit to dissociate ourself from the trade association and related activities or, in extreme cases, renounce our mandates within the organization and/or our membership. After our review, we pursued our work with all the organizations included in the scope to close the gaps and push for more alignment with our positions and commitments on climate policies. As a result, seven out of ten organizations that had not developed net-zero roadmaps three years ago, have now issued and published their roadmaps[1]. Two organizations that did not formally declare their support for the Paris Agreement have formalized their positions since. Holcim commits to continually assess the climate policy positions of our trade association and memberships on a periodic basis.

https://www.holcim.com/sites/holcim/files/2024-04/28022024-holcim-report-non-financial-matters-2023.pdf

Updates on advocacy initiatives supporting our climate change strategy are regularly presented to our main governing bodies, Board of Directors and the Executive Committee. [...] At Group level, the Group Public Affairs department is responsible for the coordination of advocacy actions within LafargeHolcim and holds direct and specific responsibility for climate change related issues. The Public Affairs function ensures alignment on climate policy positions in all parts of the company by sharing on a regular basis position papers and by engaging with the internal lobbying and advocacy network through calls, webinars and newsletters. Positions on policy issues are validated by the relevant internal experts (sustainability, waste management, finance, innovation, etc.) and made available to the Public Affairs community across the Group.

https://www.holcim.com/sites/holcim/files/documents/lafargeholcim_cdp_climate_change_2020.pdf

###### ADVOCACY POSITIONS AND TRANSPARENCY

Globally, the political and industrial agenda is firmly moving towards one of green growth. Initiatives such as Europe's Green Deal and the US Inflation Reduction Action are anchored on decoupling economic growth from carbon emissions and resource use.

At Holcim, our "Strategy 2025 – Accelerating Green Growth" and beyond are fully aligned with such initiatives:

- **[We put decarbonization at the heart of our ]**
**industrial and commercial strategy from the**
deployment of Carbon Capture Utilization and
Storage (CCUS) technologies to low-carbon
solutions such as ECOPact.

- **[We drive circular construction to build better ]**
**with less Recycling construction and**
demolition waste and enabling smart
technology, such as 3D printing that reduces the
use of materials by up to 50 percent.

- **[We develop solutions to make cities greener]**
**from foundation to rooftop and empower**
society with smarter infrastructure.

This journey requires radical collaboration with
our entire value chain and with regulators. In
particular we need regulatory frameworks that:

- **[Help us build the business case to invest at ]**
**scale in decarbonized technologies (e.g.**
competitive access to decarbonized energy /
facilitated access to funding / viable framework
for the reuse of industrial CO2).

- **[Lead to market demand for decarbonized and]**
**circular solutions (e.g. harmonized products**
standards / ambitious building codes such as
the French Environmental Regulation in 2020 /
public procurement that is technology neutral,
based on lifecycle performance and not
material specific in order to drive innovation).

- **[Enable industry to remain competitive on the]**
**global stage (e.g. international level playing**
field on carbon costs / fair state aid rule for
energy-intensive sectors / dynamic carbon
pricing).

###### CARBON CAPTURE UTILIZATION AND STORAGE (CCUS)

The European regulatory framework that is
currently being developed will play a fundamental
role in enabling the CCUS industry to be the
central engine of this low carbon and circular
transition. One decarbonization lever that is
fundamental to the sector's transition is CCUS. No
single solution will be perfectly scalable
everywhere as different environments present
different conditions (e.g. technological,
geological and legislative) that will be favorable
for one solution or another. This requires a flexible
yet unequivocal regulatory framework:

- **[Recognizing carbon use ]**

As an integral part of the transition to net zero is
a necessity as is avoiding the design of
restrictive regulatory frameworks that prevent
the scale-up of industrial carbon capture
projects. Policies under development (e.g. on
synthetic fuels in EU) cast serious doubts on the
future of CO2 utilization from industrial sources,
without any serious impact assessment.

- **[A dynamic, accessible and competitive value ]**
**chain for CO2 transport and storage**
Europe must focus on securing accessible
infrastructure for carbon capture, transport and
storage. The current monopolistic environment
threatens the viability of many projects that
would otherwise be implemented before 2030
and which require planning, permitting and
financing now.

- **[European Innovation Fund and CCUS ]**

In 2022, Holcim secured two investments from
the European Union (EU) Innovation Fund for
breakthrough CCUS projects in Germany and
Poland. Both projects feature scalable
technologies to put Holcim at the forefront of
Europe's decarbonization. Holcim's cement

plant in Lägerdorf, Germany, received EUR
110m and is part of the "Carbon 2 Business"
industry collaboration and uses Oxyfuel
technology and carbon capture for further
processing into methanol fuel or as raw material
in the chemical industry. The EU provided
funding of EUR 228m to Holcim's
Go4ECOPlanet project in Poland, which aims to
create an end-to-end Carbon Capture and
Storage (CCS) chain starting from CO2 capture
from its site in Kujawy to offshore storage in the
North Sea, with the vision to be a net-zero plant
by 2027. We are working on further investment
to enable the expansion and acceleration of our
CCUS strategy.

###### MARKET DEMAND FOR LOW CARBON PRODUCTS AND SOLUTIONS

Holcim is committed to leading the transition
toward low-carbon and circular construction by
developing and introducing green products and
solutions worldwide. In most cases, introducing
them to the market requires an adapted product
standard and its use must be facilitated by
building codes and (public) procurement
practices in order to create market demand.

- **[Create market demand through a dynamic ]**
**standardization and public procurement**
**framework. Having standards in place and**
implemented swiftly is fundamental to start
building a supply-demand momentum in the
value chain that can be supported by (public)
procurement practices and building codes.

- **[The use of harmonized product standards ]**
**remains the most appropriate approach. In**
Europe, our experience with EN 197-6 for the
use of recycled concrete fines in cement shows
that a non-harmonized approach hampers
effectiveness, speed of deployment and
cross-country optimization within the single
market. All difficulties encountered nowadays
to make applicable harmonized standards
should be solved in close cooperation with
industry as soon as possible without
unnecessary legal complexity nor multiplication
of regulations. We fully support the Biden
administration's establishment of lower
emission standards through executive orders
like Buy Clean. Our products can help them
reach their targets with our industry-leading
green building solutions.

###### CARBON BORDER ADJUSTMENT MECHANISM (CBAM)

**A fast and "watertight" implementation is key to**
**its success. A swift implementation of the CBAM**
will provide the necessary foundations for large
scale investments in the decarbonization of our
activities and products across the EU. It requires
close collaboration with the sectors concerned, in

order to make sure that adequate (existing)
standards are used (eg. on GHG measurement,
monitoring and reporting) and all potential
circumvention routes are effectively closed. This
process is fundamental to ensuring effective CO2
cost equalization.

###### LIFE CYCLE PERFORMANCE AS BASIS FOR THE FUTURE OF CONSTRUCTION

**Decarbonizing construction and making the**
**value chain truly circular does not rely on a single**
**technology or sub-sector. All materials and all**
technologies are part of the solution.

A policy framework and vision is needed that is
based on technology neutrality and lifecycle
performance. Defining the lifecycle performance
that needs to be achieved to be aligned with 1.5°C
will lead to a dynamic market based on innovation
and performance.

An example is the French Environmental
Regulation 2020 building code that has
introduced carbon footprint thresholds on the
construction part from 1 January 2022. This
lifecycle methodology makes the French market
structured around the CO2 performance at the
build scale which allows us to accelerate the
deployment of low carbon solutions.

###### ENERGY

Access to competitive decarbonized energy is a
critical enabler to the decarbonization of the
industry:

- **[A well-functioning and interconnected ]**
**electricity market where there is access to**
decarbonized energy at scale and at
competitive prices is the cornerstone for the
decarbonization of European industry and its
short and long-term competitiveness.

- **[Investments in renewable energy assets should ]**
**be facilitated through faster permitting**
procedures, including for the development of
renewable assets in industrial contexts.

- **[Industry also requires continued access to ]**
**non-recyclable waste and biomass waste.**
These resources currently supply a large
proportion of the cement sector's fuel needs,
allowing it to become less dependent on
imported fossil fuels while decarbonizing our
processes.

###### FUNDING FOR DECARBONIZED INDUSTRIAL GROWTH

In order to build strong business cases and ensure
the deployment of low carbon technology,
industry requires access to combined sources of
funding. This can be facilitated through:

###### ADVOCACY CONTINUED

###### CONTINUED

- **[A simplified application and approval process ]**

to funding sources, allowing transparent and
easy access. A shift to direct funding of CCUS
for the cement industry can accelerate the
construction phase of CCUS projects and hence
the decarbonization in the US plants.

- **[In Europe, a swift deployment of Carbon ]**
**Contracts for Difference (CCFDs) at EU and**
national level to allow for a de-risking of projects
based on access criteria that are simple and fast
in execution.

###### TRADE ASSOCIATION CLIMATE REVIEW

Our commitment to climate related reporting is
transparent and rigorous and we take the same
approach in our advocacy positions.

Aligned with our net-zero pledge, Holcim is
committed to ensure that our direct and indirect
lobbying through trade associations are aligned
with the Paris Agreement and Holcim's positions
outlined below.

- [Support of the Paris Agreement's climate]
targets and net-zero agenda.

- [Support of the use of carbon pricing ]
mechanisms.

- [Development of an industry roadmap to ]
net-zero.

- [Acknowledgement of the need of advanced]
technologies, including CCUS, to further
decarbonize (mainly for cement industry
associations).

- [Support of the need to introduce low-carbon ]
and/or net-zero products on the market.

We selected the most significant organizations,
ensuring a balanced geographical distrubution
and including global, regional and national
organizations, together representing represent c.
80% of the total amount that the Group paid to
trade organizations in 2022.

The organizations were assessed by reviewing
their public positions using their website, media
releases, publications, social media,
questionnaires and, when needed, discussions
with the local teams.

We recognize that the journey to net zero requires
radical collaboration across our entire value chain
and with regulators, investors, NGOs, civil
societies and employees. We are committed to
work with these stakeholders and our trade
associations to accelerate that journey. Where any

###### ADVOCACY

selected organizations had material misalignment
or diverging views with Holcim's policy positions
and could not be considered to be part of the
acceleration to net zero we will dissociate ourself
from the trade association and related activities
or, in extreme cases, renounce its mandates within
the organization and/or its membership.

After this review, we pursued our work with all the
organizations included in the scope to close the
gaps and push for more alignment with our
positions and commitments on Climate Policies.
As a result, five out of nine organizations that had
not developed net-zero roadmaps 2 years ago,
have now issued and published their roadmaps,
while two are no longer associated with Holcim.
Two organizations that did not formally declare
their support to the Paris agreement have
formalized their positions since. We will continue
to assess the climate policy positions of our trade
association memberships on a periodic basis.

###### CASE STUDY: HOLCIM CLIMATE- RELATED LOBBYING ACTIVITIES IN 2022

As part of its activities to advocate global
emissions reductions and the reaching of the Paris
Agreement, in 2022 Holcim attended COP27 with
the participation of our various team members
(including Holcim's Chief Sustainability and
Innovation Officer) in various panel discussions
and roundtables regarding the decarbonization of
the built environment, industrial decarbonisation
and the rolling-out of next generation
technologies and circular cities. In 2022, our CEO
was mobilized on the occasion of the New York
Climate Week, advocating for the collaboration of
all sectors in decarbonizing cities and supporting
ambitious climate-focused policies such as
support for the US Inflation Reduction Act (IRA).

Throughout 2023 we were actively involved in the
work of recognized and leading organizations on
sustainable construction, industrial
decarbonisation and the decarbonisation of the
built environment. This includes the World
Business Council for Sustainable Development
(WBCSD), the World Green Building Council
(WGBC), UNIDO's Industrial Deep Decarbonisation
Initiative (IDDI) or the Leadership Group for
Industrial Decarbonisation (LeadIT).

Holcim has signed the UN Global Compact,
supporting its ten principles on human rights,
labor, environment and anti-corruption. In parallel
to our role as a global leader, we engage bilaterally
in our markets with governments on climate policy
agenda.

Holcim has driven decarbonization discussions in
Industry Trade Associations such as Cembureau
in Europe and Global Cement and Concrete
Association at a global level. We are actively
engaged in the development of an ambitious
climate policy framework globally, at regional
levels (e.g. Europe) and national levels (e.g. USA).
Some of the topics that Holcim engages on
include carbon capture, utilization and storage
(CCUS) related policies, carbon pricing schemes,
the development of competitive decarbonised
energy networks, the achievement of common

definitions and standards of low-carbon cement
(within our industry and with external
organisations such as the First Movers Coalition of
Concrete Zero). We are actively advocating for
public procurement frameworks to embed low
carbon and circular solutions. In Europe, we have
actively engaged and supported the development
of the EU's Carbon Border Adjustment Mechanism
(CBMA, both as Holcim and through our European
Trade association Cembureau).

https://www.holcim.com/sites/holcim/files/2024-02/31032023-holcim-climate-report-2022.pdf

Holcim's climate advocacy is led by Group Public Affairs, supported by Group Sustainability and regional experts. Our approach consists of defining priorities aligned with the 1.5°C agenda and scalable actions as well as sharing advocacy guidance through a public affairs network for consistent local engagement. [...] Governed by a "Responsible Lobbying Directive," Holcim commits to dealing transparently and fairly in all its lobbying activities and complies with all applicable laws. This includes adherence to public codes of conduct and lobbying registers, where those exist. For example, Holcim's climate advocacy activities are disclosed in the EU Transparency Register. Furthermore, participation in industry and business associations is subject to mandatory compliance training and regular review.

https://www.holcim.com/sites/holcim/files/docs/28022025-holcim-non-financial-matters-report-2024.pdf

Trade Association Climate Review In support of our advocacy positions, in 2020, we assessed the memberships in our main trade organizations around the world to ensure that there are no major misalignments with the Group's policy positions on climate change. We selected 20 organizations that reflect both the size of the Group's financial contribution to the organizations (above CHF 250,000) and the Group's geographical footprint. All in all, these organizations represented roughly 80% of the total amount that the Group paid to trade organizations in 2020. The organizations were assessed by reviewing their public positions using their website, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs team. Five criteria, based on our net-zero pledge and policy enablers, were at the core of this assessment: - support of the Paris Agreement and net-zero agenda - support of the use of carbon pricing mechanisms - development of an industry roadmap to net-zero - acknowledgement of the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations) - support of the need to introduce low-carbon and/or net-zero products on the market. It was found that none of the selected organizations had material misalignment or diverging views with Holcim's policy positions. Should major divergences in position appear, Holcim will dissociate itself from the trade association's position and related activities or, in extreme cases, renounce its mandates within the organization and/or its membership. After this review, we decided to pursue our work with all the organizations included in the scope. The Group intends to be an active contributor to the climate roadmaps that some of these organizations are currently working on. We will continue to assess the climate policy positions of our trade association memberships on a periodic basis.

https://www.holcim.com/sites/holcim/files/2024-02/08042022-holcim-climate-report-2021.pdf

**_●_** **_Advocacy:_** To ensure that our direct and indirect advocacy through trade associations are aligned with the Paris Agreement, we commit to publish a regular review of our climate-related public positions at corporate level and for our main markets. We also commit to publish a biannual review of the positions of the main trade organizations we are a member of to verify that there are no major misalignments with the Group's positions on climate change. [...] ### Responsibility 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 Board's Health, Safety and Sustainability Committee (HSSC); Chief Executive Committees in countries where we operate take responsibility and are accountable for assessing and addressing local climate performance.

https://www.holcim.com/sites/holcim/files/2023-04/holcim_climate_policy.pdf

Aligned with our net-zero pledge, Holcim is committed to ensure that our direct and indirect lobbying through trade associations are aligned with the Paris Agreement and Holcim's positions outlined below.

1. Support of the Paris Agreement's climate targets and net-zero agenda
2. Support of the use of carbon pricing mechanisms
3. Development of an industry roadmap to net-zero by 2050
4. Acknowledgement of the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations)
5. Support of the need to introduce low-carbon products on the market

We selected the most significant organizations, ensuring a balanced geographical distribution and including global, regional and national organizations, together representing represent c. 80% of the total amount that the Group paid to trade organizations in 2022. The organizations were assessed by reviewing their public positions using their website, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs teams.

We recognize that the journey to net zero requires radical collaboration across our entire value chain and with regulators, investors, NGOs, civil societies and employees. We are committed to work with these stakeholders and our trade associations to accelerate that journey. Where any selected organizations had material misalignment or diverging views with Holcim's policy positions and could not be considered to be part of the acceleration to net zero we will dissociate ourself from the trade association and related activities or, in extreme cases, renounce its mandates within the organization and/or its membership.

After this review, we pursued our work with all the organizations included in the scope to close the gaps and push for more alignment with our positions and commitments on Climate Policies. As a result, 5 out of 9 organizations that had not developed net-zero roadmaps 2 years ago, have now issued and published their roadmaps, while two are no longer associated with Holcim. Two organizations that did not formally declare their support to the Paris agreement have formalized their positions since. We will continue to assess the climate policy positions of our trade association memberships on a periodic basis.

https://www.holcim.com/sites/holcim/files/2023-03/holcim_public_policy-march-2023.pdf

Holcim advocates for climate policy positions that enable: [...] Holcim's public policy positions and its climate advocacy activities are systematically underpinned by the Group SBTi's 1.5°C roadmap and associated targets, which are externally verified and fully aligned with the Paris Agreement. Review of the climate policy positions of trade associations and industry bodies entails a review of our own policy position and confirms their alignment to the Paris Agreement and net-zero agenda. [...] Aligned with our net-zero pledge, Holcim is committed to ensuring that our direct and indirect lobbying through trade associations is aligned with the Paris Agreement and Holcim's positions outlined below. [...] We selected the most significant organizations, ensuring a balanced geographical distribution and including global, regional and national organizations. The organizations were assessed by reviewing their public positions using their websites, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs teams. [...] Where any selected organizations has material misalignment or diverging views with Holcim's policy positions and cannot be considered to be part of the acceleration to net zero, we commit to dissociate ourself from the trade association and related activities or, in extreme cases, renounce our mandates within the organization and/or our membership. [...] After our review, we pursued our work with all the organizations included in the scope to close the gaps and push for more alignment with our positions and commitments on climate policies. As a result, seven out of ten organizations that had not developed net-zero roadmaps three years ago, have now issued and published their roadmaps[1]. Two organizations that did not formally declare their support for the Paris Agreement have formalized their positions since. Holcim commits to continually assess the climate policy positions of our trade association and memberships on a periodic basis.

https://www.holcim.com/sites/holcim/files/2024-04/28022024-holcim-climate-report-2023.pdf

Climate policy advocacy governance Holcim's climate advocacy is led by Group Public Affairs, supported by Group Sustainability and regional experts. Our approach consists of defining priorities aligned with the 1.5°C agenda and scalable actions as well as sharing advocacy guidance through a public affairs network for consistent local engagement. Governed by a "Responsible Lobbying Directive," Holcim commits to dealing transparently and fairly in all its lobbying activities and complies with all applicable laws. This includes adherence to public codes of conduct and lobbying registers, where those exist. For example, Holcim's climate advocacy activities are disclosed in the EU Transparency Register. Furthermore, participation in industry and business associations is subject to mandatory compliance training and regular review. [...] Industry associations review Holcim is committed to ensuring that our advocacy through trade associations is aligned with the Paris Agreement and Holcim's positions. We conduct an annual trade association review focused on: - Support for the Paris Agreement's climate ambition and net-zero agenda. - Support for carbon pricing mechanisms. - The need to develop 2050 decarbonization roadmaps. - Acceptance of the need to deploy advanced technologies, including CCUS. - Support for the creation of demand-pull policies for low-carbon products. We are committed to working with our trade associations to accelerate that journey. We address misalignment with associations or, if necessary, reconsider our membership. Additional details regarding our climate advocacy and our trade association review are available in our Climate Policy Engagement Report.

https://www.holcim.com/sites/holcim/files/docs/28022025-finance-holcim-fy-2024-report-en.pdf

Aligned with our net-zero pledge, Holcim is committed to ensure that our direct and indirect lobbying through trade associations are aligned with the Paris Agreement and Holcim's positions outlined below: 1. Support of the Paris Agreement's climate targets and net-zero agenda 2. Support of the use of carbon pricing mechanisms 3. Development of an industry roadmap to net-zero by 2050 4. Acknowledgement of the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations) 5. Support of the need to introduce low-carbon products on the market We selected the most significant organizations, ensuring a balanced geographical distribution and including global, regional and national organizations. The organizations were assessed by reviewing their public positions using their website, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs teams. We recognize that the journey to net zero requires radical collaboration across our entire value chain and with regulators, investors, NGOs, civil societies and employees. We are committed to work with these stakeholders and our trade associations to accelerate that journey. Where any selected organizations had material misalignment or diverging views with Holcim's policy positions and could not be considered to be part of the acceleration to net zero we commit to dissociate ourselves from the trade association and related activities or, in extreme cases, renounce its mandates within the organization and/or its membership. After this review, we pursued our work with all the organizations included in the scope to close the gaps and push for more alignment with our positions and commitments on Climate Policies. As a result, seven out of ten organizations that had not developed net-zero roadmaps three years ago, have now issued and published their roadmaps. Two organizations that did not formally declare their support to the Paris agreement have formalized their positions since (more details in Annex 2). Holcim commits to continually assessing the climate policy positions of our trade association and memberships on a periodic basis. Holcim's public policy positions and its climate advocacy activities are systematically underpinned by the Group SBTi's 1.5°C roadmap and associated targets, which are externally verified and fully aligned with the Paris Agreement. The review of the climate policy positions of trade associations and industry bodies entails a review of our own policy position and confirms their alignment to the Paris Agreement and net zero agenda.

https://www.holcim.com/sites/holcim/files/2024-02/climate-public-policy-positions.pdf

Aligned with our net-zero pledge, Holcim is committed to ensure that our direct and indirect lobbying through trade associations are aligned with the Paris Agreement and Holcim's positions outlined below: 1. Support of the Paris Agreement's climate targets and net-zero agenda 2. Support of the use of carbon pricing mechanisms 3. Development of an industry roadmap to net-zero by 2050 4. Acknowledgement of the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations) 5. Support of the need to introduce low-carbon products on the market We selected the most significant organizations, ensuring a balanced geographical distribution and including global, regional and national organizations. The organizations were assessed by reviewing their public positions using their website, media releases, publications, social media, questionnaires and, when needed, discussions with the local public affairs teams. We recognize that the journey to net zero requires radical collaboration across our entire value chain and with regulators, investors, NGOs, civil societies and employees. We are committed to work with these stakeholders and our trade associations to accelerate that journey. Where any selected organizations had material misalignment or diverging views with Holcim's policy positions and could not be considered to be part of the acceleration to net zero we commit to dissociate ourselves from the trade association and related activities or, in extreme cases, renounce its mandates within the organization and/or its membership. After this review, we pursued our work with all the organizations included in the scope to close the gaps and push for more alignment with our positions and commitments on Climate Policies. As a result, seven out of ten organizations that had not developed net-zero roadmaps three years ago, have now issued and published their roadmaps. Two organizations that did not formally declare their support to the Paris agreement have formalized their positions since (more details in Annex 2). Holcim commits to continually assessing the climate policy positions of our trade association and memberships on a periodic basis. Holcim's public policy positions and its climate advocacy activities are systematically underpinned by the Group SBTi's 1.5°C roadmap and associated targets, which are externally verified and fully aligned with the Paris Agreement. The review of the climate policy positions of trade associations and industry bodies entails a review of our own policy position and confirms their alignment to the Paris Agreement and net zero agenda.

https://www.holcim.com/sites/holcim/files/2024-02/climate-public-policy-positions.pdf

Governed by a "Responsible Lobbying Directive", Holcim commits to dealing transparently and fairly in all its lobbying activities and complies with all applicable laws. This includes adherence to public codes of conduct and lobbying registers, where those exist. For example, Holcim's climate advocacy activities are disclosed in the EU Transparency Register. Furthermore, participation in industry and business associations is subject to mandatory compliance training and regular review. [...] Holcim is committed to ensuring that our advocacy through trade associations is aligned with the Paris Agreement and Holcim's positions. We conduct an annual trade association review focused on: - Support for the Paris Agreement's climate ambition and net-zero agenda. - Support for carbon pricing mechanisms. - The need to develop 2050 decarbonization roadmaps. - Acceptance of the need to deploy advanced technologies, including CCUS. - Support for the creation of demand-pull policies for low-carbon products. We are committed to working with our trade associations to accelerate that journey. We address misalignment with associations or, if necessary, reconsider our membership.

https://www.holcim.com/sites/holcim/files/docs/28022025-holcim-climate-report-2024.pdf

Holcim's climate advocacy is led by Group Public Affairs, supported by Group Sustainability and regional experts. Our approach consists of defining priorities aligned with the 1.5°C agenda and scalable actions as well as sharing advocacy guidance through a public affairs network for consistent local engagement. Governed by a "Responsible Lobbying Directive", Holcim commits to dealing transparently and fairly in all its lobbying activities and complies with all applicable laws. This includes adherence to public codes of conduct and lobbying registers, where those exist. For example, Holcim's climate advocacy activities are disclosed in the EU Transparency Register. Furthermore, participation in industry and business associations is subject to mandatory compliance training and regular review. [...] Holcim is committed to ensuring that our advocacy through trade associations is aligned with the Paris Agreement and Holcim's positions. We conduct an annual trade association review focused on: - Support for the Paris Agreement's climate ambition and net-zero agenda. - Support for carbon pricing mechanisms. - The need to develop 2050 decarbonization roadmaps. - Acceptance of the need to deploy advanced technologies, including CCUS. - Support for the creation of demand-pull policies for low-carbon products. We are committed to working with our trade associations to accelerate that journey. We address misalignment with associations or, if necessary, reconsider our membership. Additional details regarding our climate advocacy and our trade association review are available in our Climate Policy Engagement Report.

https://www.holcim.com/sites/holcim/files/docs/28022025-holcim-climate-report-2024.pdf

To further strengthen our advocacy voice, in 2021 we decided to review our memberships in trade associations and industry bodies to ensure that there are no major gaps between their climate policy positions and our own policy positions. None of the selected organizations had material misalignment or diverging views with Holcim's policy positions. However, some organizations did not have formal positions on some of the topics assessed. In the following years we closely collaborated with trade bodies to accelerate and strengthen their commitments and ensure an ongoing and more streamlined alignment with our climate policy positions. [...] The analysis was then reviewed with the Group's sustainability and stakeholder engagement team. [...] Holcim works to ensure that the positions of these organizations are aligned to its own while working in full respect of the governance rules in place in all trade associations. The Group's main policy positions are made available externally on its website and circulated to its internal public affairs network on a regular basis. Should major divergences in positions appear, Holcim will work proactively with the organization in question to find alignment. If no alignment can be found, Holcim will dissociate itself from the organization in question and related activities, or in extreme cases renounce its mandates within the undergoes regular assessment of the organizations it is a member of, to evaluate benefits and risks of its memberships. In case of major misalignment with an organization, the Group is ready to quit the organization, as it has done in the past. In 2021, following a careful review assessment of its organizations in the USA, Holcim decided to leave an industry organization due to misalignments on climate positions.

https://www.holcim.com/sites/holcim/files/2024-04/holcim-2023-industry-associations-climate-review.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]In September 2020, Holcim was the first global building materials company to sign the UN Global Compact's "Business Ambition for 1.5°C" initiative, with a 2030 SBTi-verified targets. As part of this net zero climate pledge, Holcim has identified key policy enablers that form the core of its policy positions and advocacy, including:

– Effective carbon pricing mechanisms
– Market demand for low-carbon products and solutions
– Large-scale deployment of advanced technologies, such as carbon capture usage and storage (CCUS)

In support of this commitment and associated policy enablers, Holcim decided to assess its memberships in its main trade organizations around the world. The aim was to ensure that those organizations have no major misalignment with the Group's policy positions on climate change.

To proceed with this assessment, Holcim has analyzed its memberships around the world and made a selection of 20 organizations. Those were selected to reflect both the size of the Group's financial contribution to the organizations (above CHF 250,000) and the Group's geographical footprint. All in all, these organizations represent c. 80% of the total amount that the Group paid to trade organizations in 2020.

The core review was led by the corporate public affairs team based on the organizations' public positions, on their website, media releases, publications and social media. A questionnaire was also sent to the organizations based on the five criteria (see below) to complement the analysis and give the opportunity to bring additional positions into the review. When needed, a discussion was organized with the local public affairs team to ensure a good understanding of the policy landscape and alignment in the analysis. The analysis was then reviewed with the Group's sustainability and stakeholder engagement team.

Should major divergences in positions appear, Holcim will work proactively with the organization in question to find alignment.

If no alignment can be found, Holcim will dissociate itself from the organization in question and related activities, or in extreme cases, renounce its mandates within the organization and/or its membership.

CDP Questionnaire Response 2022

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023

MEMBERSHIPS IN TRADE ASSOCIATIONS AND INDUSTRY BODIES

Review of Climate Policy Positions

May 2023

Table of contents

03 A foward by Magali Anderson

04 Holcim's Trade Associations Climate Review

06 2023 Update of Trade Associations Climate Policy Review

07 Overview of the main outcomes of review

08 Holcim's approach to advocacy and government affairs

08 Targeted engagement with diverse stakeholders

09 Advocating in support of Holcim's policy positions

2 Table of contents

Magali Anderson, Chief Sustainability and Innovation Officer

3 A foreword By Magali Anderson

Climate action is at the core of Holcim's "Strategy 2025 – Accelerating Green Growth", to become the global leader in innovative and sustainable building solutions. With our 60,000 colleagues, we are on a mission to decarbonize building across its life cycle to build cities that work for people and the planet. We are accelerating our net-zero journey to decarbonize Holcim.

Taking a science-driven approach, we upgraded our climate targets to align them with the 1.5°C framework and validated them with the Science Based Targets initiative. We are making progress in carbon capture, utilization and storage, and committed to invest CHF 2 billion by 2030 in mature technologies to capture more than 5 million tons of CO2 per year. We closely monitor any developments concerning climate-related issues by engaging with investors and analysts, nongovernmental organizations, policy makers and trade associations.

To further strengthen our advocacy voice, in 2021 we decided to review our memberships in trade associations and industry bodies to ensure that there are no major gaps between their climate policy positions and our own policy positions. None of the selected organizations had material misalignment or diverging views with Holcim's policy positions. However, some organizations did not have formal positions on some of the topics assessed. In the following years we closely collaborated with trade bodies to accelerate and strengthen their commitments and ensure an ongoing and more streamlined alignment with our climate policy positions.

Holcim's Trade Associations

Climate Review

We are committed to align our climate policy actions and positions with the Paris Agreement's objective of limiting global warming to 1.5°. This commitment was translated into continuous and progressive efforts to achieve this goal at Holcim. At Holcim, we take a rigorous science-driven approach to become a net-zero company, ensuring that our targets and actions are in line with the 1.5°C framework.

- In 2020, we were the first global building solutions company to sign the United Nations Global Compact (UNGC)'s "Business Ambition for 1.5°C" initiative, with intermediate 2030 targets approved by the SBTi in alignment with a net-zero pathway. - In 2021, our 2050 CO2 targets were among the first long-term targets validated by SBTi, consistent with the new net-zero standard across all scopes, setting a reference for our industry. - In 2022, we upgraded our 2030 climate targets and validated them with the SBTi, in line with our sector's new 1.5°C science-based framework.

This commitment is fully reflected in our (public policy) positions as well as our direct and indirect engagement with external stakeholders.

Methodology & scope

In support of this commitment and associated policy enablers, Holcim has decided to assess its memberships in its main trade organizations around the world. The aim was to ensure that those organizations have no major misalignment with the Group's policy positions on climate change.

To proceed with this assessment, in 2021 Holcim has analyzed its memberships around the world and made a selection of 20 organizations. Those were selected to reflect both the size of the Group's financial contribution to the organizations (above CHF 250,000) and the Group's geographical footprint. All in all, these organizations represent c. 80% of the total amount that the Group paid to trade organizations in 2020. Map of organizations reviewed in 2021 4 Holcim's Trade Associations Climate Review The core review was led by the corporate public affairs team based on the organizations' public positions, on their website, media releases, publications and social media. A questionnaire was also sent to the organizations based on the five criteria (see below) to complement the analysis and give the opportunity to bring additional positions into the review. When needed, a discussion was organized with the local public affairs team to ensure a good understanding of the policy landscape and alignment in the analysis. The analysis was then reviewed with the Group's sustainability and stakeholder engagement team.

Each organization has been assessed according to five criteria, based on Holcim's net zero climate pledge and policy enablers:

– Supports Paris Agreement and net zero agenda

i.e. does not deny the need to have climate policies and to progress towards a net zero world

– Supports the use of Carbon Pricing Mechanisms

i.e. support the implementation of carbon price through market mechanisms (e.g. EU ETS) or fiscal mechanisms (e.g. carbon taxes) as a tool to deliver a net zero economy

– Existence of a climate net zero roadmap (mainly for cement industry associations)

i.e. has developed (or is in the process of developing) the industry roadmap to net zero i.e. supports the view that advanced technologies, including CCUS, will be needed to decarbonize hard-to-abate sectors like ours

– Acknowledge the need of advanced technologies, including CCUS, to further decarbonize (mainly for cement industry associations)

– Supports the need to introduce low-carbon and/or net zero products on the market

i.e. considers it has an active role to develop the regulatory framework to incentivize the development of markets for low-carbon and/or net zero materials and solutions Given that the organizations selected have various scopes (cement associations, ready-mix industry representatives, multi-sectoral business organizations) and diverse regulatory environments (different levels of government commitments to climate policy and carbon pricing), some of the topics are not covered by all the organizations. This policy landscape was considered in the review of each organization.

5 Holcim's Trade Associations Climate Review

2023 Update of Trade Associations Climate Policy Review

In 2021, Holcim committed to pursue its work with all the organizations included in the scope of the review. Throughout 2022, Holcim carried out a regular follow up on the identified gaps in each organization. The number of reviewed organizations reduced from 20 to 17 organizations due to the divestments of Holcim operations in India and Brazil. As a result of the new review, among the 17 trade associations, five out of eight that did not have net-zero roadmaps in 2021 have now completed and published their roadmaps (where two - UNICEM in France and economiesuisse in Switzerland- are not scoped in netzero roadmaps). The two organizations NRMCA in USA, and CCAA in Australia that did not have a formal position on the Paris Agreement, have now formalized their positions; while GCCA (Global Cement & Concrete Alliance) formalized its position on Carbon Pricing Mechanism.

6 2023 Update of Trade Associations Climate Policy Review Specifically on each topic: – Paris Agreement: There is a unanimous support to the principles of climate policy and decarbonization of our industry, and all organizations have taken a formal position on the Paris Agreement.

– Carbon pricing: All organizations engage with governments and stakeholders on carbon pricing mechanisms when there is a regulatory project. Some have a reactive approach.

– Net zero roadmap: With few explain, all organizations have or are planning a climate roadmap (in most cases taking the full value chain in consideration). CEMBUREAU and GCCA's work in this area is driving and informing many of the national initiatives.

– Advanced technologies: Almost all organizations surveyed engage proactively on the development and deployment of advanced technologies for decarbonization, including Carbon Capture Usage and Storage.

– Low-carbon products: All organizations are active in promoting low-carbon products, including through the regulatory framework and public procurement.

OOvveerrvviieeww ooff tthhee mmaaiinn oouuttccoommeess ooff tthhee rreevviieeww

Supports Paris Agreement and net-zero agenda

Supports the use of Carbon Pricing Mechanisms

EU

Cembureau

Yes

Worldwide

GCCA

Yes

Yes Yes

Existence of a net-zero Yes roadmap (for cement industry association)

Acknowledge the need of advanced technologies, including CCUS, to further decarbonize

Supports the need to introduce low-carbon and/or net-zero products on the market

Yes

Yes

Yes

Yes

Yes

Switzerland

Cemsuisse Economiesuisse

Yes Yes

Yes Yes

Yes - Waiting confirmation

Yes

No formal position

Yes

UK

Mineral Products Association

Yes

Yes

Yes

Yes

Yes Yes Yes

Spain

Oficemen

Yes

Yes

Yes

Yes

Yes

Supports Paris Agreement and net-zero agenda

Supports the use of Carbon Pricing Mechanisms

Germany

VDZ

Yes

Poland Austria

Stowarzyszenie Producentów Cementu

Yes

VOZ

Yes

Yes Yes Yes

Existence of a net-zero Yes Yes roadmap (for cement industry association)

Acknowledge the need of advanced technologies, including CCUS, to further decarbonize

Supports the need to introduce low-carbon and/or net-zero products on the market

Yes

Yes

7 Overview of the main outcomes of review

Yes

Yes

Yes

Yes

Yes

USA

NRMCA

Yes

No formal position

Yes

Yes

Canada

Cement Association of Canada

Yes

Yes

Yes

Australia

Cement, Concrete & Aggregates Australia

Yes

No formal position

No

Yes Yes

Yes Yes Yes

Belgium

Febelcem

Yes

Yes

Yes

Yes

Yes

SFIC

Yes

Yes

Yes

Yes

France

UNICEM

Yes

Yes

No formal position

No formal position

Yes Yes

New Zealand

Concrete NZ

Yes

Yes

Yes

Yes

Yes

Phillipine

Cement Manufacturers of the Philippines

Yes

No formal position

No

CEMAP is committed to the Net-Zero, no roadmap due to lack of resources

No formal position

Yes

Yes No Work in Progress Other

Holcim's approach to advocacy and

government affairs

As the world's global leader in building solutions, Holcim engages with public authorities around the world on issues that are relevant to its business activities. The Group is committed to giving reliable and up-to-date information to public authorities. The Group remains politically neutral, supports freedom of expression and respects other stakeholders' rights to express their opinions and positions. The Group does not make political donations, unless it is expressly permitted under written local laws and applicable Holcim policies and guidelines, and transparently and accurately recorded.

Those principles form part of the Group's Responsible Lobbying and Advocacy Directive. The Directive is applicable to all Holcim employees engaging with Public Authorities. Holcim has a strict Anti-Bribery & Corruption policy that applies to its lobbying and advocacy activities. Annual training is conducted in countries on the Anti-Bribery & Corruption policy. To ensure compliance with its policies, the Group has a number of tools and procedures in place such as the Minimum Control Standards and the Integrity Line. Holcim enrolls in lobbying and transparency registers where applicable and where it exists. By way of example, Holcim is a participant of the EU Transparency Register, where advocacy activities, priorities and estimated spending in EU affairs are listed.

Targeted engagement with diverse stakeholders

Holcim engages with a diversity of stakeholders active or influential on policy regulations that are linked to its activities: – National authorities, government officials, members of Parliament, regional and local authorities where the Group operates – Trade and business organizations in operating countries (e.g. Canada Association of Cement, economiesuisse), at regional (e.g. EU's CEMBUREAU) and global level (e.g. Global Cement and Concrete Association, World Business Council for Sustainable Development) – International coalitions (e.g. Carbon Pricing Leadership Coalition, Global Alliance for Buildings and Construction) – Multilateral bodies (e.g. UN agencies, OECD) – Think tanks and NGOs (e.g. Business for Nature Bellona)

The Group is a member of 281 organisations in 50+ countries. Holcim Group companies reported spending CHF 17.8 million on direct advocacy activities in 2022.

8 Holcim's approach to advocacy and government affairs

Advocating in support of Holcim's policy positions

Employees within Holcim designated to engage with public uthorities are clearly identified. In countries, Country CEOs (CCEO) are accountable for dvocacy activities. Holcim requires that any third-party that engages with public authorities on its behalf undergo due diligence.

When possible, Holcim aims to have a proactive role in the organizations, associations and coalitions it is a member of (board membership, working group chairmanship, active membership, etc.). Employees that are active in trade associations that Holcim is a member of or associated with are systematically engaging in a way that reflects

9

Holcim's positions and ambitions.

Holcim works to ensure that the positions of these organizations are aligned to its own while working in full respect of the governance rules in place in all trade associations. The Group's main policy positions are made available externally on its website and circulated to its internal public affairs network on a regular basis.

Should major divergences in positions appear, Holcim will work proactively with the organization in question to find alignment.

If no alignment can be found, Holcim will dissociate itself from the organization in question and related activities, or in extreme cases, renounce its mandates within the organization and/or its membership. Holcim undergoes regular assessment of the organizations it is a member of, to evaluate benefits and risks of its memberships. In case of major misalignment with an organization, the Group is ready to quit the organization, as it has done in the past. In 2021, following a careful review assessment of its organizations in the USA, Holcim decided to leave an industry organization due to misalignments on climate positions.

Contact us at Holcim

Head of Public Affairs

Cédric De Meeûs cedric.demeeus@holcim.com

Engagement/Advocacy Report