Barry Callebaut AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Barry Callebaut provides a very detailed picture of its climate-related lobbying. It names several identifiable policies and initiatives it tries to shape, including the EU Regulation on deforestation-free products (EUDR), the proposed EU Corporate Sustainability Due Diligence Directive, and the Cocoa & Forests Initiative Frameworks for Action, as well as its role in the EU-led “Cocoa Talks” and the Côte d’Ivoire-Ghana Cocoa Initiative Economic Pact. The company also spells out how it seeks to influence these measures: it refers to four years of advocacy on the EUDR carried out through “steering committees, working groups, and regular meetings in origin countries,” bi-weekly technical discussions coordinated by the World Cocoa Foundation, direct engagement with EU policymakers through the Alliance on Sustainable Cocoa, and months of dialogue that culminated in a Memorandum of Understanding with the Government of Côte d’Ivoire. Finally, Barry Callebaut is explicit about the results it is pursuing, such as “an end to the conversion of any forest land for cocoa production,” “a moratorium on the traceable direct sourcing of cocoa from national parks and reserves,” achieving “100 % traceability for our direct supply chain,” and using due-diligence legislation to create “a level playing field for all companies.” By naming the policies, disclosing the mechanisms and targets of engagement, and linking them to concrete, measurable outcomes, the company demonstrates a comprehensive level of transparency around its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Barry Callebaut indicates that it has established protocols to align its policy-influencing activities with its sustainability objectives by stating that “all our direct and indirect activities that influence policy are consistent with our overall strategy,” and by assigning the External Affairs function the role to “coordinate messaging with key stakeholders including policy makers.” The company further illustrates this alignment through an example where a Memorandum of Understanding with the Government of Côte d’Ivoire underwent “3+ months of engagement and coordination” to ensure that agreed points were “consistent with our sustainability goals including climate change goals.” These disclosures demonstrate a clear commitment to align both direct and indirect lobbying with its climate-related strategy. However, Barry Callebaut does not disclose any formal sign-off or ongoing monitoring procedures for lobbying activities, such as routine reviews or audits, nor does it identify a specific individual or formal committee that oversees lobbying governance. We found no evidence of a dedicated climate-lobbying report or third-party audit, or of processes to engage or exit industry associations whose positions may conflict with its climate objectives, indicating that the governance framework lacks detailed oversight responsibilities and explicit monitoring mechanisms.	2