Eramet SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Eramet provides some insight into how it keeps its external engagement activities in step with its climate ambitions, noting that "Eramet has implemented mechanisms to ensure that all its activities support the mitigation of climate change" and that these mechanisms "are reviewed by the CEO" while "the Board is directly involved in influencing such activities so that they remain aligned with the company’s strategy and policies on climate change." The company explains that its climate-change policy "contains guidelines concerning climate change which apply to all Eramet businesses and countries in which we operate" and states that these principles are "regularly reviewed, improved and approved by management," indicating an internal process for checking alignment. It also names senior‐level oversight, stating that "Eramet’s commitment to climate change is managed by its senior executives" and that the Board provides direct involvement, which points to a defined governance structure. However, the disclosure does not spell out how the company specifically monitors or manages the content of its direct lobbying positions, nor does it describe any systematic review of the climate positions of trade associations or other indirect lobbying channels; no information is provided on corrective actions or escalation if misalignment is found, and the company acknowledges that it has "No" public commitment to conduct engagement in line with the Paris Agreement. Overall, this indicates that while Eramet discloses a policy framework and names accountable parties, the details of how lobbying—particularly indirect lobbying—is tracked and aligned are limited and not publicly reported. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Eramet provides some insight into how it keeps its external engagement activities in step with its climate ambitions, noting that "Eramet has implemented mechanisms to ensure that all its activities support the mitigation of climate change" and that these mechanisms "are reviewed by the CEO" while "the Board is directly involved in influencing such activities so that they remain aligned with the company’s strategy and policies on climate change." The company explains that its climate-change policy "contains guidelines concerning climate change which apply to all Eramet businesses and countries in which we operate" and states that these principles are "regularly reviewed, improved and approved by management," indicating an internal process for checking alignment. It also names senior‐level oversight, stating that "Eramet’s commitment to climate change is managed by its senior executives" and that the Board provides direct involvement, which points to a defined governance structure. However, the disclosure does not spell out how the company specifically monitors or manages the content of its direct lobbying positions, nor does it describe any systematic review of the climate positions of trade associations or other indirect lobbying channels; no information is provided on corrective actions or escalation if misalignment is found, and the company acknowledges that it has "No" public commitment to conduct engagement in line with the Paris Agreement. Overall, this indicates that while Eramet discloses a policy framework and names accountable parties, the details of how lobbying—particularly indirect lobbying—is tracked and aligned are limited and not publicly reported.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Eramet SA offers a highly transparent picture of its climate-policy lobbying. It names multiple concrete files it engages on, including New Caledonia’s energy-transition plan, the EU Battery Directive, the revision of the Waste Shipment Regulation and the EU taxonomy for sustainable activities, allowing each piece of legislation to be clearly identified. The company also details the channels it uses and the decision-makers it targets, citing the “signing of a MOU to facilitate the emergence of renewable energies on New Caledonian territory,” “exchanges with European parliamentarians, the European Commission and Member States,” “exchanges with the Joint Research Center (JRC),” the drafting of “position papers with French authorities,” and participation in the battery industry group RECHARGE. Finally, it spells out the outcomes it seeks—for example, advocating “higher recycling rates” than those proposed by the European Commission in the Battery Directive, proposing specific “criteria… for climate and environmental objectives of the taxonomy,” aiming to “limit exports of intermediate products” under the Waste Shipment Regulation, and facilitating renewable-energy deployment in New Caledonia. By clearly linking policies, mechanisms and desired results, Eramet demonstrates a comprehensive level of transparency in its climate-related lobbying activities.	A