Danone SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Danone discloses a well-structured governance system that explicitly seeks to keep both direct and trade-association lobbying aligned with its Paris-aligned climate strategy. The company states that "Danone's Advocacy Policy defines the scope of Danone's advocacy activities and the way in which these should be conducted transparently and ethically" and notes that "any climate related advocacy is coordinated through the central team to ensure a common approach," showing the presence of a formal process for monitoring direct lobbying. Oversight responsibilities are clearly assigned: "Danones Corporate Affairs and Compliance Departments are co-responsible for overseeing the worldwide implementation of our companys advocacy policies," while "any new climate advocacy engagements or partnerships are reviewed and validated by the Global Engagement Committee" and "an update on all of our policies is presented annually at the CSR Committee, which is a specialized Committee of the Board," indicating board-level supervision as well as executive-level review. For indirect lobbying, Danone confirms that it systematically assesses and manages alignment with industry bodies, stating that "in 2023, we will review our advocacy policy to include measures to ensure alignment between our policy positions and those of our trade associations" and that "as part of our annual disclosure to the CDP, we already evaluate alignment between the Paris Agreement, our own advocacy and the advocacy of the trade associations." The company describes concrete steps for addressing misalignment, such as "verbalizing our position, ensuring any disagreement is noted in the official minutes sending a formal letter and if applicable considering our own submission to a public consultation," which demonstrates an active mechanism to correct conflicts. Regular training ensures implementation: "Regular trainings are rolled-out by both the compliance and public affairs teams to ensure professionals are trained on the practice of advocacy." This indicates a robust governance framework that actively monitors and aligns both direct and indirect lobbying activities with its climate-related objectives. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Danone discloses a well-structured governance system that explicitly seeks to keep both direct and trade-association lobbying aligned with its Paris-aligned climate strategy. The company states that "Danone's Advocacy Policy defines the scope of Danone's advocacy activities and the way in which these should be conducted transparently and ethically" and notes that "any climate related advocacy is coordinated through the central team to ensure a common approach," showing the presence of a formal process for monitoring direct lobbying. Oversight responsibilities are clearly assigned: "Danones Corporate Affairs and Compliance Departments are co-responsible for overseeing the worldwide implementation of our companys advocacy policies," while "any new climate advocacy engagements or partnerships are reviewed and validated by the Global Engagement Committee" and "an update on all of our policies is presented annually at the CSR Committee, which is a specialized Committee of the Board," indicating board-level supervision as well as executive-level review. For indirect lobbying, Danone confirms that it systematically assesses and manages alignment with industry bodies, stating that "in 2023, we will review our advocacy policy to include measures to ensure alignment between our policy positions and those of our trade associations" and that "as part of our annual disclosure to the CDP, we already evaluate alignment between the Paris Agreement, our own advocacy and the advocacy of the trade associations." The company describes concrete steps for addressing misalignment, such as "verbalizing our position, ensuring any disagreement is noted in the official minutes sending a formal letter and if applicable considering our own submission to a public consultation," which demonstrates an active mechanism to correct conflicts. Regular training ensures implementation: "Regular trainings are rolled-out by both the compliance and public affairs teams to ensure professionals are trained on the practice of advocacy." This indicates a robust governance framework that actively monitors and aligns both direct and indirect lobbying activities with its climate-related objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Danone provides a highly detailed picture of its climate-policy advocacy. It names a wide range of specific measures it has engaged on, including the U.S. Inflation Reduction Act, the Infrastructure Investments and Jobs Act, Colorado’s HB 22-1355 Extended Producer Responsibility law, the Clean Air Act, EPA proposals on waste-prevention and recycling, EU Green Deal Farm-to-Fork and Biodiversity 2030 strategies, forthcoming EU deforestation legislation, the Global Biodiversity Framework’s Target 15, and EU corporate-accountability rules, among many others. The company is equally explicit about how it lobbies and who it targets: it describes letters sent by RE100 members to the leaders of the U.S. Senate and House, formal comment submissions to the U.S. Department of Labor, the U.S. State Department and the EPA, one-on-one meetings with European Commission Vice-President Frans Timmermans and other EU officials, sign-on calls initiated by MEP Pascal Canfin, participation in congressional advocacy days, and wider coalition activity through bodies such as the World Business Council for Sustainable Development and the Sustainable Food Policy Alliance. These disclosures are supported by public registration in the EU Transparency Register, France’s HATVP and the U.S. Lobbying Disclosure Act, and by the publication of the position papers it provides to public authorities. Finally, Danone sets out the concrete policy changes it is seeking: it urges governments to “develop and implement national food strategies” and to integrate food into NDCs and NAPs, calls for “mandatory human rights and environmental due diligence” in EU law, supports keeping Extended Producer Responsibility in the New York State budget “to help fund much-needed infrastructure improvements,” backs raising the EU 2030 GHG reduction target to at least 55%, and presses for regulation of GHG emissions under the Clean Air Act, among other clearly articulated goals. Taken together, these disclosures demonstrate a comprehensive level of transparency across the policies lobbied, the mechanisms employed and the outcomes sought.	A