Estee Lauder Cos Inc/The

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate Estée Lauder Companies gives a reasonable level of visibility into which climate-related public policies it engages on, naming the EU Green Deal, the emerging UN Global Plastics Treaty and a series of U.S. state proposals covering circular-economy and climate-reporting requirements. The company is most explicit about how it seeks to influence these files: it describes using several channels—“meetings”, “coalition letters”, and advocacy conducted through trade associations such as the Personal Care Products Council and Cosmetics Europe—and identifies the policymaking targets as EU institutions, individual member states and U.S. state lawmakers. Where the disclosure is less developed is on the results it is trying to secure; beyond stating that it “supports with minor exceptions” the EU Green Deal and that the Plastics Treaty should remain “aligned with the Paris Agreement”, the company does not spell out concrete legislative amendments, quantitative targets or other measurable outcomes it is advocating. Overall the disclosure demonstrates solid transparency on mechanisms and a fair listing of the policies involved, but only high-level statements about the policy changes it wants to see. 2
Lobbying Governance
Overall Assessment Comment Score
Strong Estee Lauder Cos Inc appears to have a defined governance process to ensure its external engagement, including direct and indirect lobbying, aligns with its climate commitments, with oversight by a named board committee and senior executives. For example, “ELC’s participation in climate change policy is led by the Global Corporate Citizenship and Sustainability and Global Public Affairs teams,” and these functions “align with internal stakeholders as well as external associations and partners to support or shape those efforts,” while “our public policy priorities are reviewed periodically with leadership for alignment with our goals and commitments.” The company also demonstrates attention to indirect lobbying by noting that “we are a member of several trade organizations with climate-related policies that align with ours,” and it invests senior leadership in monitoring these activities through the Nominating & ESG Committee of the Board, which “has oversight responsibility for our Company’s environmental, social, and governance activities and practices, including citizenship and sustainability matters.” However, the company does not disclose a detailed mechanism for assessing or exiting associations whose positions might conflict with its climate policy, nor does it publish an independent audit or report explicitly evaluating the alignment of its lobbying activities with its climate goals or require formal board sign-off on specific climate lobbying plans. 3