Adidas AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Adidas AG provides detailed disclosures of its climate policy lobbying activities, demonstrating a comprehensive approach to transparency. The company clearly names several specific climate policies it has engaged on, including the US EPA’s Clean Power Plan and multiple EU legislative initiatives—among them the Corporate Sustainability Due Diligence Directive, the Corporate Sustainability Reporting Directive, the EU Strategy for Sustainable and Circular Textiles, the Ecodesign for Sustainable Products Regulation, the Waste Framework Directive, Extended Producer Responsibility Schemes, the Product Environmental Footprint, and the Green Claims Directive. It also describes its lobbying mechanisms and targets, stating that it “directly engages with EU policy makers” through its membership of FESI (Federation of the European Sporting Goods Industry), participates in “regular meetings with political stakeholders and discussions around legislative acts,” and joins “open public consultations” and “expert webinars/groups organized by the European Union,” while similarly supporting a letter of endorsement to the US EPA. Finally, adidas is explicit about the outcomes it seeks, such as questioning “the value of including the climate change factor in the framework of the Corporate Sustainability Due Diligence Directive (CSDDD),” proposing that “other initiatives on the EU level can address this issue more effectively,” backing the development of a guidance package for standardized Product Life Cycle Assessments (with a preference against mandatory implementation), and advocating for more robust renewable energy regulations.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Adidas appears to have moderate governance processes to align its lobbying activities with its climate commitments, but does not disclose a dedicated oversight structure or a climate-specific lobbying review. The company discloses its lobbying activities in Germany, the EU and the United States in official registers and relies on a “Government Affairs Policy” and “Compliance Policy” that set “clear guardrails for engaging with governments, authorities and public officials.” It further states that it “refer[s] to these commitments when engaging with policymakers,” invoking its public commitment to the Paris Agreement and its participation in the “UN Fashion Industry Charter for Climate Action (UNFCCC)” and the “Fashion Pact” as guiding reference points. Its guidelines also specify that “membership in these associations is guided by our Association Membership Policy, Government Affairs Policy, and Compliance Policy,” with memberships “coordinated globally and reviewed on an annual basis,” showing a process for indirect lobbying through trade and industry bodies. We found no evidence of a named individual or formal body responsible for overseeing the alignment of lobbying with climate objectives, nor of a published audit or report evaluating its climate lobbying alignment.	2