Umicore SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Umicore discloses extensive information on every dimension of its climate-policy lobbying. It names the specific legislative files it targets, including the draft EU Battery Regulation and its secondary rules on recycling efficiency, the Euro 7 emissions standard, the EU Hydrogen Strategy, the European Innovation Partnership on Raw Materials, and the Materials Roadmap of the EU’s Strategic Energy Technologies Plan, giving clear insight into the exact policies on which it seeks to exert influence. The company also explains how and where it lobbies: it submits written comments, takes part in "formal and informal stakeholder meetings with JRC and the Commission," and works indirectly through "active participation" in the EIP on Raw Materials and as a "leading member of EMIRI, the Energy Materials Industrial Research Initiative," while monitoring similar initiatives in North America and East Asia. In addition, Umicore is explicit about the outcomes it is pursuing, such as advocating for a "CO2-footprint declaration of battery production," "lower emission targets in Euro 7," and "more ambitious targets" within the Battery Regulation, alongside its broader objective of high-efficiency recycling to close material loops. These detailed disclosures demonstrate a comprehensive level of transparency about both the company’s lobbying activities and the climate-related policy changes it is striving to achieve.	4

Lobbying Governance

Overall Assessment	Comment	Score
None	Umicore SA outlines its thematic focus areas for engagement but does not disclose any internal processes or oversight to ensure these advocacy efforts align with its climate change strategy. It states that "We engage consistently with and through governments, trade associations and industry alliances in order to reduce the use of primary materials and increase the use of recycled materials," and highlights that "Our advocacy focuses on clean mobility (lower emissions, electric mobility and hydrogen based mobility) and responsible sourcing, i.e. conflict minerals and battery regulations." However, the company does not describe any policy framework, defined review or monitoring procedures, or identify who oversees its lobbying activities to ensure alignment with its climate goals, and there is no mention of board oversight, executive responsibility, or mechanisms for assessing or managing its indirect lobbying through trade associations.	0