Air Liquide SA

Lobbying Governance

AI Extracted Evidence Snippet Source

We engage with public authorities in a constructive and transparent manner, following ethical rules and applying complete neutrality. All of our actions respect the official lobbying regulations enforced in the countries in which we are present. [...] 1st release of the main professional organizations of which Air Liquide is a member

https://usa.airliquide.com/sites/al_us/files/2023-03/air-liquide-sustainability-report-2022.pdf

Following the first climate review of our main associations performed in 2022, we extended the scope of the study to cover in 2023 following geographies: USA, France, Europe (EU level), Germany, South Africa, Korea, Japan, China and Australia. Inline with the principles described in our charter available on our website, we reviewed some of our main associations operating in their geographies regarding their alignment with the Paris Agreement and Air Liquide's climate-related positions thanks to following table: [...] Among the 33 associations reviewed this year, we found 27 alignments, 5 part-alignments and 1 misalignment. [...] Air Liquide Action: Following the 2022 climate review, Air Liquide has engaged in 2023 with the leadership of the association to request a clearer and explicit support to the Paris agreement and endorsement of Air Liquide climate-related positions. In 2024, Air Liquide is no longer a member of AFPM.

https://www.airliquide.com/sites/airliquide.com/files/2024-03/air-liquide-trade-associations-climate-review-eng-2023-2.pdf

The representation of the Group in its contacts with public stakeholders, be they institutional as well as NGOs, civil society, professional associations and think tanks, is coordinated by the corporate European and International Affairs Department and its representatives in different geographical areas. This department analyzes potential changes in public policies and ensures the contribution of Air Liquide to public authorities consultations when it is relevant. [...] Our principles of engagement with public stakeholders were published on our website for the first time in December 2021. Since this date, Air Liquide is keeping its website up to date by describing its Principles of engagement, its Organization and its Ethics and Transparency rules in terms of public affairs as well as its main actions in terms of climate advocacy. [...] The representation of the Group in its contacts with public stakeholders, be they institutional as well as NGOs, civil society, professional associations and think tanks, is coordinated by the European and International Affairs Department and its representatives in different geographical areas to support our engagement policy. For instance, the role of the European and International Affairs Department is to analyze any potential changes in public policies, to maintain the right balance between short- and long-term response, and the consistency of messages across the Group, the business lines and its different geographies. This Department is also in charge of ensuring the answers to public authorities consultations where Air Liquide's expertise is recognized when complex debate or policy making work require it. For example, Air Liquide has been invited by the French government to co-chair the National Hydrogen Council whose mission is to bring together a comprehensive ecosystem of industrial and institutional stakeholders to advise the ministers and the administrative bodies in charge of the hydrogen strategy. [...] Regarding safety and environmental impact, our ambition is to advance industrial gas standards as well as the regulations related to energy transition in the countries where we operate. To this end, and in its relationships with public stakeholders, Air Liquide scrupulously respects the fundamental principles of its code of conduct and complies with the legislation in force. [...] Before joining any new association, each Air Liquide entity shall verify the climate objective positions of such association. Memberships are reported on a yearly basis to the European and International Affairs Department by the different Air Liquide Entities across the world. [...] We publish a yearly review of our main associations in geographies where Air Liquide is mostly interacting with public stakeholders. This selection is based on the relevance of the associations to Air Liquide activities, the level of Air Liquide participation in their working groups, as well as their contribution to the public debate related to climate and environmental topics. This review will be progressively extended. Our team, at corporate and local levels, are reviewing the positions of our main associations using a multi-source content (ex: Association website, publications or public positions) in order to assess: 1. Explicit alignment with Paris agreement's goals or contribution to net zero pathways as outlined by the International Energy Agency. 2. Alignment with Air Liquide's advocacy positions on climate (as described above). [...] When an association is considered as aligned, Air Liquide will continue to actively engage and contribute to their work while reviewing its alignment on a regular basis. When an association is considered as partly aligned or misaligned, Air Liquide will engage discussions with the association's leadership and will request the association to explicitly support the Paris Agreement. Air Liquide will also discuss possible ways forward with the association to confirm its Climate-related positions to influence the association. When engaging with a partly aligned or misaligned association is not resulting in a satisfactory change of such associations' position or when Air Liquide considers that such engagement is unlikely to succeed, Air Liquide will consider terminating its membership in such association. Air Liquide will report its actions to address any misalignment between its climate-related positions and the ones of its trade associations, coalitions, alliances or funded think tanks.

https://www.airliquide.com/sites/airliquide.com/files/2023-12/charter-engagement-with-public-stakeholders-dec-2023-eng.pdf

# II. TAXATION - LOBBYING

**3.** **Questions from Trusteam Finance (Climate Action 100 +)**

- Lobbying on Climate change:

- Will Air Liquide commit to conduct all of its lobbying activities in line with the goals of the Paris
agreement?

Yes, it is already the case: all lobbying activities are in line with the Group's strategy which is committing to
carbon neutrality.

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- Will Air Liquide commit to ensure that the trade associations the company is a member of lobby in line
with the goals of the Paris Agreement?

Yes, we are carrying out for the main trade association where we are active, reviews of trade associations
positions regarding the Paris agreement, and we will publish a synthetic overview of our survey for the
associations where we are the most active in Europe and in the US.

- Will Air Liquide publish a Review of Climate Lobbying, including a list of at least the 15 most important
associations?

Yes, we will extend the publication of the list of the main business associations (already mentioned in our
charter on Engagement with Public Stakeholders) where we are active in the field of energy transition, and
will publish by the end of 2022 a synthesis of our analysis of their positions, as mentioned above.

- Do you publish a responsible lobbying charter? Are you members of any professional associations that

[...]

Since 2020, the Group has consolidated its internal organization within the European and International
Affairs Department in order to ensure that the messages conveyed by Air Liquide to the public authorities
are in line with its own sustainable development objectives. At present, ten or so individuals work in Paris
and Brussels to promote these interactions with the public authorities.

[A responsible lobbying charter was published on the Group's web site at the end of 2021 (engagement with](https://www.airliquide.com/sustainable-development/engagement-public-stakeholders)
[public stakeholders) which provides details concerning the manner in which the Air Liquide Group](https://www.airliquide.com/sustainable-development/engagement-public-stakeholders)
conducts its actions in order to contribute to public debate in areas where the Group has a legitimate
interest.

This also involves reinforcing the governance of our participations within professional associations in order
to ensure actively that they are aligned with our own sustainable development objectives and, in particular,
our carbon neutrality trajectory in line with the Paris Agreement.

The Group plans to gradually extend these analyses in 2022 and to publish a summary report on the main
associations to which the Group actively contributes, specifying where appropriate the actions taken when
we consider that the position adopted by certain associations is not consistent with our own carbon
neutrality objectives.

https://www.airliquide.com/sites/airliquide.com/files/2022-05/replies-to-questions-asked-prior-to-the-2022-agm.pdf

We have also continued to implement our extensive plan to better structure our advocacy actions and to strengthen our governance for Public Affairs. This plan includes notably : **1)** the review of our internal organization to reinforce the alignment and consistency of our messages across the Group under the Control of the corporate Public Affairs department; **2)** the preparation and the publication of our "engagement with public stakeholders" statement in the form of a Public Affairs Charter published internally and externally; **3)** the enhancement of the governance of our memberships in associations including prioritization, due diligence to check for compliance with Air Liquide's strategy and with the Paris Agreement and monitoring. [...] **1)** **Public Affairs organization and advocacy positioning** As stated in our previous letter issued in November 2020, the Group has strengthened its Public Affairs organization with a corporate team in charge of supervising the 3 main areas where our lobbying efforts are conducted: Energy transition, Innovation and Technology, and Healthcare. 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. The corporate Public Affairs team also ensures alignment with geographies, mainly Europe, the US, Japan, China and Korea, which are the most advanced geographies for energy transition and hydrogen. This setup has allowed us to have a better control on various actions and messages broadcasted by our entities around the world. [...] A thorough review of Public Affairs activities was held in 2021 with the Group's Audit Committee, where processes and governance were addressed. [...] **2)** **Engagement with stakeholders** We have published, in December 2021, our statement on "engagement with public stakeholders" on our website[2], and we thank you for your appreciation regarding this statement which is covering the principles and organization of our advocacy activities based on our transparency and ethics fundamentals. This engagement is also giving more insight about our memberships in some of the prominent associations in France, in Europe and in the United States where we are actively contributing to the dialogue with public stakeholders. It also clarifies that our advocacy efforts towards policy makers, either directly or indirectly, are all carried out in full alignment with the principles presented in our statement of engagement with public stakeholders. [...] **3)** **Governance of memberships with associations** Following our continued efforts in 2021 to structure our advocacy activities in full alignment with our climate objectives, Air Liquide intends to continue advocating for ambitious actions that would contribute to accelerate the energy transition in line with the Paris agreement. We have in this respect given full consideration to the points raised in your letter and emails regarding the scope of the monitoring of trade associations[3] and the vigilance regarding positions taken by trade associations in regards to the Paris agreement objectives. In 2022, it is our intention to further strengthen the governance of our memberships in such associations globally, to ensure we dedicate our efforts in organizations that are aligned with our own commitments as stated above. In particular, we will specifically perform necessary Due Diligences to monitor policy positions of the 5 top associations in Europe and in the US, and extend progressively the range of our monitoring to all the main associations by 2023. Due to the intensity of policy making both in the EU and in Europe, this represents a significant effort that we feel is a good opportunity to continue strengthening our processes for the efficiency of our advocacy efforts in the long term. We will address specifically the case of some US associations in order to assess whether or not it still makes sense for us to continue our membership, should we assess that such associations are not aligned with our positions.

https://www.airliquide.com/sites/airliquide.com/files/2022-06/reply-to-letters-from-investors-iigc-february-2022.pdf

The Group's lobbying activities are fully aligned with the Group's ADVANCE strategy, in particular the commitment to achieve carbon neutrality by 2050. The Group published its Public Affairs Charter at the end of 2021, [that is available on the Group web site and provides details of our rules and principal policies for](https://www.airliquide.com/sustainable-development/engagement-public-stakeholders) engagement with public stakeholders, together with our organization. [...] Yes, Air Liquide analyses the positions of the professional associations in which the Group participates with regard to the objectives of the Paris Agreements and the Group's climate positions. In 2022, Air Liquide carried out its first review of the climate positions of its main associations in the United States, France and Europe, since these are the most important regions in terms of its interaction with public authorities. This review of the 16 principal associations in these regions, and the associated methodology, is available on [the Group's public affairs page. This review will be extended to other regions over the next few years as](https://www.airliquide.com/sustainable-development/engagement-public-stakeholders) the process gathers momentum.

https://www.airliquide.com/sites/airliquide.com/files/2023-05/replies-to-questions-asked-prior-to-the-2023-agm.pdf

The representation of the Group in its contacts with public stakeholders, be they institutional as well as NGOs, civil society, professional associations and think tanks, is coordinated by the corporate European and International Affairs Department and its representatives in different geographical areas. This department analyzes potential changes in public policies and ensures the contribution of Air Liquide to public authorities consultations when it is relevant. [...] Our principles of engagement with public stakeholders were published on our website for the first time in December 2021. Since that date, Air Liquide is keeping its website up to date by describing its Principles of engagement, its Organization and its Ethics and Transparency rules in terms of public affairs as well as its main advocacy actions. [...] The role of the European and International Affairs Department encompasses the analysis of any potential changes in public policies, to maintain the right balance between short and long-term responses, and the consistency of messages across the Group, the business lines and its different geographies. This Department is also in charge of providing answers to public authorities consultations where Air Liquide's expertise is recognized. For example, Air Liquide has been invited by the French government to co-chair the National Hydrogen Council whose mission is to bring together a comprehensive ecosystem of industrial and institutional stakeholders to advise the ministers and the administrative bodies in charge of the hydrogen strategy. [...] Regarding safety and environmental impact, our ambition is to advance industrial gas standards as well as the regulations related to energy transition in the countries where we operate. To this end, and in its relationships with public stakeholders, Air Liquide scrupulously respects the fundamental principles of its code of conduct and complies with the legislation in force. [...] In some countries or geographies where they engage with other stakeholders, companies are required by the law to register themselves in transparency registers. The Air Liquide Group complies with these provisions by reporting its activities and actions to the public authorities. [...] As we serve many industrial sectors in many different geographies and activities, we rely on and take part in various trade association working groups. We request that all our associations, globally, explicitly align with the Paris agreement's goals or contribute to net zero pathways as outlined by the International Energy Agency. We precise below the process in place towards associations to monitor their alignments with Paris agreement's goals and with Air Liquide's climate-related positions. [...] Before joining any new association, each Air Liquide entity shall verify the climate objective positions of such association. Memberships are reported on a yearly basis to the European and International Affairs Department by the different Air Liquide Entities across the world. [...] Our teams, at corporate and local levels, are reviewing the positions of our main associations using a multi-source content (ex: Association website, publications or public positions) in order to assess: 1. Explicit alignment with Paris agreement's goals or contribution to net zero pathways as outlined by the International Energy Agency. 2. Alignment with Air Liquide's advocacy positions on climate (as described above). [...] When an association is considered as partly aligned or misaligned, Air Liquide will engage discussions with the association's leadership and will request the association to explicitly support the Paris Agreement. Air Liquide will also discuss possible ways forward with the association to confirm its Climate-related positions to influence the association. When engaging with a partly aligned or misaligned association is not resulting in a satisfactory change of such associations' position or when Air Liquide considers that such engagement is unlikely to succeed, Air Liquide will consider terminating its membership in such association.

https://www.airliquide.com/sites/airliquide.com/files/2024-12/2024-public-affairs-charter-and-report-engagement-with-public-stakeholders-2024.12-eng-version.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]To contribute to a sustainable future in line with the Paris agreement, Air Liquide has made the commitment to reach carbon neutrality by 2050, to fight climate change, contribute to the energy transition, and to include healthcare, human resources and governance as part of its ESG (Environmental, Social and Governance) objectives. Engaging with policy makers is one way to achieve such goals by explaining and supporting our actions. All advocacy and lobbying activities are conducted according to these commitments.

Our engagement relies on the belief that private actors bring expertise to the public debate by presenting arguments and assessments of the implications of policies to the policy makers, in particular when policy decisions may have consequences on the company's activities and on other external stakeholders, or could, for example, compromise the ability of industries to reach their decarbonization commitments.

The representation of the Group among its stakeholders, be they institutional as well as NGOs, civil society, professional associations and think tanks, is defined and put in place by the Corporate European and International Affairs Department and its representatives in different geographical areas to support our engagement policy: the department analyzes any potential changes in public policies and ensures the response to the Public Authorities to the consultations where Air Liquide's expertise is recognized when complex debate or policy making work require it.

Our behavior and actions are driven by the principles of integrity and transparency that are, for governments, civil societies and companies, increasingly necessary. In this framework, integrity refers to the honesty and impartiality expected in companies' decisions and actions, whereas transparency means sincerity and openness. To this end, in some countries or geographies where they engage with other stakeholders, companies are required by the law to register themselves in transparency registers. The Air Liquide Group complies with these provisions by regularly reporting its activities and actions to the public authorities.
In December 2021, Air Liquide went one step further, by detailing, on its Website, its Principles of actions, Organization and Ethics and Transparency rules in terms of public affairs as well as its main actions in terms of climate advocacy in line with the Paris agreement.
https://www.airliquide.com/sustainable-development/engagement-public-stakeholders

CDP Questionnaire Response 2022

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]We ask all our associations, globally, to explicitly align with the Paris agreement's goals or contribute to net zero pathways as outlined by the International Energy Agency.

CDP Questionnaire Response 2023

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023

Published December 2023 - Updated 27/03/24 (V1.1)

Air Liquide - Trade Associations - Climate Review 2023

Following the first climate review of our main associations performed in 2022, we extended the scope of the study

to cover in 2023 following geographies: USA, France, Europe (EU level), Germany, South Africa, Korea, Japan, China and Australia.

Inline with the principles described in our charter available on our website, we reviewed some of our main

associations operating in their geographies regarding their alignment with the Paris Agreement and Air Liquide's climate-related positions thanks to following table:

Table 1: Matrix used to review alignment of main associations in 2023 climate review

Alignment with the Paris Agreement

Support for the temperature goal of the Paris Agreement

Support the goal to hold the increase in the global average temperature to well below 2°C above pre-industrial levels and pursue efforts to limit the temperature increase to 1.5°C above pre-industrial levels.

Support policies that accelerate the deployment of low

Hydrogen pcarorbdouncedanthdrouregnheewleacbtlreolyhsyisdraongdennat(uinrcallugdainsgwithhydcraorgbeonn capture and storage (CCS))

Alignment with main Air Liquide's climate-related positions

Electrification

CCUS

Support accelerating electrification using renewable and low-carbon energy sources.

Support policies providing long term visibility on price and volumes for energy-intensive industries.

Support policy mechanisms to encourage deployment of CCUS, in particular for the hard-to-abate sector.

Carbon pricing bSruopapdoerrt ppoulitctiyngfraamperwicoerkontocaacrhbioenveenmeits-szieornosemasispsaiortnso.f a

Among the 33 associations reviewed this year, we found 27 alignments, 5 part-alignments and 1 misalignment. Table 2 is summarizing our findings.

Mis-alignment: ● American Fuel & Petrochemicals Manufacturer (AFPM) - USA

○ Assessment: At Air Liquide's request, AFPM added a statement to their website noting, "AFPM supports the aspiration of the Paris Agreement to address climate change through global cooperation and greenhouse gas emissions reductions." ■ While this is an important step forward, Air Liquide believes that more should be done to better align AFPM with the goals of the Paris Agreement. ■ Notably, AFPM positioning is against regulations requiring changes in the US petrochemical industry: "We oppose regulations that make unreasonable and often conflicting demands on U.S. refiners and petrochemical manufacturers to make major changes in their processes."

2023 Air Liquide Trade Associations - Climate Review - V1.1 Page 1 Published December 2023 - Updated 27/03/24 (Updates in Yellow) - ENG

○ Air Liquide Action: Following the 2022 climate review, Air Liquide has engaged in 2023 with the leadership of the association to request a clearer and explicit support to the Paris agreement and endorsement of Air Liquide climate-related positions. In 2024, Air Liquide is no longer a member of AFPM.

Partial-alignments:

● Energy Users Association of Australia (EUAA) - AUSTRALIA

○ Assessment: Air Liquide is a member of EUAA and acknowledges its commitment to support the objectives of the Paris Agreement. We expect EUAA to act more clearly in favor of policies supporting the transition from fossil based energies to low carbon and renewable solutions. ○ Air Liquide Action: Air Liquide will continue to engage with EUAA on the decarbonisation of energy intensive industries in Australia and explain its climate-related positions in Australia.

● Japan Chemical Industry Association (JCIA) - JAPAN

○ Assessment: Air Liquide is a member of JCIA and acknowledges JCIA's commitment to support the objectives of the Paris Agreement. We expect JCIA to position more clearly in favor of adoption of carbon pricing policies and utilization of CCUS technologies for some hard-to-abate sectors. It is to be noted that we found JCIA as not opposed to these policies. ○ Air Liquide Action: Air Liquide will continue to engage with JCIA on the decarbonisation of the chemical industry in Japan and explain its climate-related positions in Japan.

● Energy Intensive Users Group of South Africa (EIUG) - SOUTH AFRICA

○ Assessment: Air Liquide is a member of the Energy Intensive Users Group of South Africa (EIUG) and notices its support to the energy transition. Air Liquide expects the association to put the energy transition to a bigger priority in its actions. ○ Air Liquide Action: Air Liquide will continue to engage with EIUG on the decarbonisation of energy intensive industries in South Africa and explain its climate-related positions in South Africa.

● National Associations of Manufacturers (NAM) - USA

○ Assessment: Air Liquide is a member of the National Association of Manufacturers (NAM) and notices that the association recognizes the need to decarbonize our economies. Air Liquide expects the association to put the energy transition to a bigger priority in its actions and take clearer positions in favor of policies addressing this issue (ex: carbon pricing, incentives on clean technologies, regulations on GHGs...). In particular, NAM was against the Inflation Reduction Act in 2022 because of the increased taxes levied on companies, which remains one of the key policies to promote low carbon technologies in the U.S. Despite these taxes, Air Liquide supports a more nuanced approach which reflects the benefits of the environmental support in the law. ○ Air Liquide Action: Air Liquide will continue to engage with NAM on such topics as well as other relevant issues for Air Liquide. In parallel, Air Liquide will continue to explain our climate-related advocacy positions in the U.S.

● US Chamber Of Commerce (USCC) - USA

○ Assessment: Air Liquide is a member of the US Chamber Of Commerce (USCC) and notices that the association recognizes the need to decarbonize our economies. Air Liquide expects the association to put the energy transition to a bigger priority in its actions and take clearer positions in favor of policies addressing this issue (ex: carbon pricing, incentives on clean technologies, regulations on GHGs...). In particular, USCC was against the Inflation Reduction Act in 2022 because of the increased taxes and its potential inflationary impact, which remains one of the key policies to promote low carbon technologies in the U.S. Despite these taxes, Air Liquide supports a more nuanced approach which reflects the benefits of the environmental support in the law. ○ Air Liquide Action: Air Liquide will continue to engage with USCC on such topics as well as other relevant issues for Air Liquide. In parallel, Air Liquide will keep explaining its climate-related advocacy positions in the U.S.

2023 Air Liquide Trade Associations - Climate Review - V1.1 Page 2 Published December 2023 - Updated 27/03/24 (Updates in Yellow) - ENG

Table 2: Summary of 2023 Associations Climate Review

Association name Geography

Australian Hydrogen Council Australia

Alignment with the Paris Agreement Aligned

Energy Users Association of Australia Australia Aligned China Petroleum and Chemical Industry Federation/CPCIF (中国石油和化学工业联合会) China Aligned Association of International Chemical Manufacturers (AICM) China Aligned European Biogas Association EU Aligned European Industrial Gases Association (EIGA) EU Aligned

European Round Table of Industrialists EU Aligned European Federation of Energy Traders (EFET) EU Aligned Hydrogen Europe EU Aligned Association française des entreprises privées (AFEP) France Aligned France Chimie France Aligned France Hydrogène France Aligned France Industrie France Aligned MEDEF France Aligned German Chemical Industry Association (VCI) Germany Aligned Federation of German Industries (BDI) Germany Aligned Association of the Industrial Energy and Power Industry (VIK) Germany Aligned Industrial Gases Association (IGV) Germany Aligned Japan Chemical Industry Association (JCIA) Japan Aligned Japan Hydrogen Association(JH2A) Japan Aligned

Association of Hydrogen Supply and Utilization Technology (HySUT): Japan Aligned Clean Fuel Ammonia Association(CFAA) Japan Aligned Japan Industrial and Medical Gases Association(JIMGA) Japan Aligned

2023 Air Liquide Trade Associations - Climate Review - V1.1 Published December 2023 - Updated 27/03/24 (Updates in Yellow) - ENG

Alignment with main Air Liquide's climate-related positions Aligned Partly Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Aligned Partly Aligned Aligned

Aligned Aligned Aligned

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Association name Geography

H2Korea Korea Energy Intensive Users Group of South Africa South Africa National Business Initiative Energy council South Africa American Chemistry Council American Fuel & Petrochemicals Manufacturer Compressed Gas Association Fuel cell & Hydrogen Energy Association National Association of Manufacturers US Chamber of Commerce

South Africa South Africa USA USA USA USA USA USA

Alignment with the Paris Agreement Aligned Partly Aligned Aligned Aligned Aligned Misaligned Aligned Aligned Partly Aligned Aligned

2023 Air Liquide Trade Associations - Climate Review - V1.1 Published December 2023 - Updated 27/03/24 (Updates in Yellow) - ENG

Alignment with main Air Liquide's climate-related positions Aligned Aligned Aligned Aligned Aligned Misaligned Aligned Aligned Partly Aligned Partly Aligned

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Engagement/Advocacy Report