Chocoladefabriken Lindt & Spruengli AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Chocoladefabriken Lindt & Sprüngli AG discloses only limited governance over its climate-related lobbying activities: it states that “we do not participate directly in political activities but may engage in debates of legitimate interest to us through trade associations” and that the “company does not use corporate funds for the express purpose of political advocacy, lobbying, or campaign contributions,” but it does not disclose any specific process to review or align these engagements with its climate commitments. Sustainability oversight is vested in the Sustainability Committee of the Board—which “guides the Board in setting the strategic direction and sustainability targets,” including climate change—and in Group Management led by the CFO, who “oversees and guides the management of sustainability matters,” yet this structure is not explicitly applied to lobbying alignment. In its CDP response, the company says it has “a public commitment or position statement in line with global environmental treaties or policy goals” and indicates it “have evaluated, and it is aligned” with the Paris Agreement for its indirect engagement via the World Cocoa Foundation and other platforms, but we found no evidence of a formal review or monitoring procedure, nor of a named individual or body tasked specifically with overseeing lobbying activities or assessing the climate policy positions of trade associations. This indicates limited governance over climate lobbying. View Sources	D

Overall Assessment

Analysis

Score

Limited

Chocoladefabriken Lindt & Sprüngli AG discloses only limited governance over its climate-related lobbying activities: it states that “we do not participate directly in political activities but may engage in debates of legitimate interest to us through trade associations” and that the “company does not use corporate funds for the express purpose of political advocacy, lobbying, or campaign contributions,” but it does not disclose any specific process to review or align these engagements with its climate commitments. Sustainability oversight is vested in the Sustainability Committee of the Board—which “guides the Board in setting the strategic direction and sustainability targets,” including climate change—and in Group Management led by the CFO, who “oversees and guides the management of sustainability matters,” yet this structure is not explicitly applied to lobbying alignment. In its CDP response, the company says it has “a public commitment or position statement in line with global environmental treaties or policy goals” and indicates it “have evaluated, and it is aligned” with the Paris Agreement for its indirect engagement via the World Cocoa Foundation and other platforms, but we found no evidence of a formal review or monitoring procedure, nor of a named individual or body tasked specifically with overseeing lobbying activities or assessing the climate policy positions of trade associations. This indicates limited governance over climate lobbying.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Lindt & Sprüngli provides only limited insight into its climate-related lobbying. It describes working through trade associations, noting that "selectively we may engage in debates of legitimate interest to us either directly or through trade associations" and that indirect engagement includes "providing feedback on sector guidance documents and input to find alignment on how best to implement legal requirements related to Deforestation and Greenhouse Gas accounting for cocoa." These statements reveal an indirect mechanism—feedback given via bodies such as the World Cocoa Foundation and SWISSCO—but they do not name the specific government agencies or legislative processes approached. Likewise, the company references broad policy themes such as deforestation rules and greenhouse-gas accounting but does not identify any particular bill, regulation, or jurisdiction. The desired outcomes are expressed only in general terms, for example supporting “ending cocoa-related deforestation and taking climate action,” without articulating the concrete regulatory changes it seeks. Because the disclosures remain high-level and omit concrete policies, targets, and intended legislative results, the company’s transparency on climate lobbying is minimal.	D