Clariant AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Clariant provides a very high level of transparency on its climate-related lobbying. It names multiple concrete files it seeks to influence, including the “EU ReFuel Aviation Regulation,” the “EU ETS and CBAM Regulations,” the “EU Renewable Energy Directive (revision),” and broader packages such as the “EU 2030 targets, Fit for 55.” The company is equally clear about how and where it lobbies, stating it carries out “direct advocacy towards EU Commission, Parliament and a number of Member States” and, when appropriate, works “via trade associations, notably CEFIC, ePure, Leaders of Sustainable Biofuels and the Advanced Biofuels Coalition.” Finally, Clariant is explicit about the changes it wants: it aims to “secure mandatory blending target at EU level as part of the Renewable Energy share in transport,” has been “calling for an additional mandatory sub-target dedicated to advanced biofuels in the ramp up of SAFs,” supports “higher targets in terms of renewable energy in transport,” and, through CEFIC, seeks “due consideration of a global playing field and protection against the risk of carbon leakage.” By disclosing the specific policies, its direct and association-based engagement channels, the institutions addressed, and the precise policy outcomes it is pursuing, the company demonstrates comprehensive transparency around its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Clariant provides only limited insight into how it governs climate-related lobbying. The disclosure notes that its “external engagement activities” are expected to be “consistent with your climate commitments and/or climate transition plan” and that this area is overseen by “The Innovation and Sustainability Committee (ISC) [which] comprises two to four members of the Board of Directors, ideally with professional experience in … sustainability, including climate risk management.” While this shows that a board-level body is assigned to review the alignment of external engagement—including lobbying—with the company’s climate objectives, the company does not disclose any further details of the process: there is no description of how the ISC monitors or approves lobbying positions, no reference to assessing trade-association memberships, and no indication of specific procedures, frequency of reviews, or corrective actions. Consequently, the evidence points to the existence of a nominal oversight body but provides no substantive information on mechanisms, monitoring, or alignment checks for either direct or indirect lobbying.	1