Koninklijke Ahold Delhaize NV

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Koninklijke Ahold Delhaize NV provides a highly detailed picture of its climate-policy engagement. It identifies several concrete files it works on, including the "EU deforestation regulation," the "EU Farm to Fork strategy," the "EU Nature Restoration Regulation," its push to "Make Food Loss and Waste Protocol mandatory for food waste reporting," and its support for “making carbon reporting mandatory for all companies,” showing that the company openly names the specific legislation it seeks to influence. The channels of influence are also described with specificity: the company notes "engaged in conversations with the European Commission officials," "outreach to members of the European Parliament," "participating in a panel discussion during a European Commission event," and that it "co-signed an open letter from business to European Union (EU) policy makers," thereby clarifying both the mechanisms (meetings, letters, public events) and the targets (European Commission officials and Members of the European Parliament). Finally, Ahold Delhaize states the concrete results it wants: it aims to "Make Food Loss and Waste Protocol mandatory for food waste reporting," seeks to "expand the scope of ecosystems included in the regulation beyond forest and other wooded lands to conversion of other natural ecosystems," calls for "applying the administrative requirements to all parties involved including SMEs to ensure the required traceability," and backs mandatory carbon reporting for all companies. By naming the legislation, the methods of engagement, and the precise policy changes it advocates, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Ahold Delhaize discloses an “internal policy on engaging with public policy makers relevant for stakeholders and our brands to adhere to when conducting any political activity or outreach,” and confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” These elements show the company has established a formal policy framework to guide its lobbying-related engagement in support of its climate objectives. However, Ahold Delhaize does not disclose any governance structures around this policy, such as a named individual or formal committee with oversight responsibility, nor does it describe any process for monitoring, reviewing, or enforcing alignment of direct or indirect lobbying activities with its climate commitments. We found no evidence of regular audits, association reviews, board-level sign-off, or criteria to assess and manage trade association involvement, which indicates the governance of climate-related lobbying activities is limited.	1