Air Liquide SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Air Liquide discloses a well-structured and transparent governance system that addresses both its own advocacy and its memberships in industry bodies, and it supports these disclosures with a published climate-lobbying review. The company states that “the corporate team ensures that advocacy messages are aligned with our ESG and business objectives, including the climate objectives, through a governance involving business and corporate stakeholders,” while the “Corporate European and International Affairs Department…is coordinated…to support our engagement policy,” showing an internal mechanism that oversees direct lobbying alignment. Oversight reaches board level, as “A thorough review of Public Affairs activities was held in 2021 with the Group’s Audit Committee, where processes and governance were addressed,” and the Public Affairs Charter is “published internally and externally,” providing clear rules and accountability. For indirect lobbying, Air Liquide runs a formal, recurring audit: “We publish a yearly review of our main associations…using a multi-source content…to assess: 1. Explicit alignment with Paris agreement’s goals…2. Alignment with Air Liquide’s advocacy positions on climate,” and the company publicly released the findings, noting that in 2023 it “reviewed 33 associations…27 alignments, 5 part-alignments and 1 misalignment.” Corrective action is demonstrated: “Air Liquide has engaged in 2023 with the leadership of the association…In 2024, Air Liquide is no longer a member of AFPM.” The policy also governs future memberships: “Before joining any new association, each Air Liquide entity shall verify the climate objective positions of such association,” and sets escalation steps when misalignment persists, including terminating membership. These disclosures go beyond commitments, providing detailed processes, responsible bodies, annual monitoring, published assessments, and evidence of action, indicating strong and comprehensive governance of both direct and indirect climate lobbying activities. No material gaps were found in the description of monitoring, oversight, or corrective processes, which indicates very strong governance. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Air Liquide discloses a well-structured and transparent governance system that addresses both its own advocacy and its memberships in industry bodies, and it supports these disclosures with a published climate-lobbying review. The company states that “the corporate team ensures that advocacy messages are aligned with our ESG and business objectives, including the climate objectives, through a governance involving business and corporate stakeholders,” while the “Corporate European and International Affairs Department…is coordinated…to support our engagement policy,” showing an internal mechanism that oversees direct lobbying alignment. Oversight reaches board level, as “A thorough review of Public Affairs activities was held in 2021 with the Group’s Audit Committee, where processes and governance were addressed,” and the Public Affairs Charter is “published internally and externally,” providing clear rules and accountability. For indirect lobbying, Air Liquide runs a formal, recurring audit: “We publish a yearly review of our main associations…using a multi-source content…to assess: 1. Explicit alignment with Paris agreement’s goals…2. Alignment with Air Liquide’s advocacy positions on climate,” and the company publicly released the findings, noting that in 2023 it “reviewed 33 associations…27 alignments, 5 part-alignments and 1 misalignment.” Corrective action is demonstrated: “Air Liquide has engaged in 2023 with the leadership of the association…In 2024, Air Liquide is no longer a member of AFPM.” The policy also governs future memberships: “Before joining any new association, each Air Liquide entity shall verify the climate objective positions of such association,” and sets escalation steps when misalignment persists, including terminating membership. These disclosures go beyond commitments, providing detailed processes, responsible bodies, annual monitoring, published assessments, and evidence of action, indicating strong and comprehensive governance of both direct and indirect climate lobbying activities. No material gaps were found in the description of monitoring, oversight, or corrective processes, which indicates very strong governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Air Liquide gives an unusually detailed picture of its climate-policy advocacy. It names a wide range of concrete measures it seeks to influence, including the European Commission’s “Clean Energy for All Package,” the EU Fit-for-55 revisions to the ETS and RED directive, the Alternative Fuel Infrastructure Regulation, the EU Net-Zero Industry Act and CBAM, France’s National Hydrogen Strategy, and U.S. legislation such as the Infrastructure Investment and Jobs Act and the Inflation Reduction Act, as well as Japan’s Green Innovation Fund. The company also describes how it engages: a corporate public-affairs team of “ten or so individuals work in Paris and Brussels to promote these interactions with the public authorities,” it co-chairs the French National Hydrogen Council, responds to European Commission consultations, meets “US Congress in Washington DC,” supplies input to the U.S. Department of Treasury on the CHIPS and Science Act, and contributes through forums such as the European Roundtable of Industrialists, the European Clean Hydrogen Alliance and the Hydrogen Council. These disclosures identify both the mechanism (direct meetings, written submissions, leadership roles in councils and trade bodies) and the specific targets (European institutions, French government, US Congress, Singapore EDB/MTI and others). Air Liquide is equally explicit about what it wants from policymakers: high and predictable carbon pricing, recognition of Carbon Contracts for Difference, public CO₂-infrastructure networks, mandates and subsidies to scale renewable and low-carbon hydrogen, and policies that will deliver the EU goal of “reducing greenhouse-gas emissions by 55 % by 2030.” By combining clear lists of the policies it lobbies, the channels it uses, and the concrete outcomes it supports or opposes, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	A