Aurubis AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Aurubis AG provides a very detailed picture of its climate-policy lobbying. It names multiple concrete files it is working on – including the European Emissions Trading System (EU-ETS), the Carbon Border Adjustment Mechanism (CBAM), the EU Circular Economy Action Plan, the EU Taxonomy for Sustainable Activities and national measures such as Carbon Contracts for Difference – and links each of them to the company’s business and transition plans. The company also explains how it lobbies: it prepares “Policy Papers, Association Work, [and] Contact with decision makers”, maintains offices in Brussels and Berlin, is listed in both the German and EU transparency registers, and engages targets such as the European Commission, European Parliament and German Bundestag as well as industry bodies like Eurometaux and the BDI. Finally, Aurubis is explicit about what it wants to achieve. It seeks to “ensure current level of Carbon-Leakage protection” in the EU-ETS, supports inclusion of copper in the EU Taxonomy along with “a separate reporting category ‘under assessment’”, backs stronger eco-design and recycling standards while “stopping illegal shipments of electrical waste”, advocates an “internationally competitive industry electricity price”, and argues that “CBAM is not a solution for the copper sector”. By naming the policies, describing the engagement channels and identifying concrete policy outcomes, the company demonstrates a comprehensive level of transparency around its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Aurubis has established a robust framework for its political engagement, grounded in its “Corporate External Affairs Policy, which defines the responsibilities, duties, and processes in this area,” and supported by a supplementary “Corporate Policy on the Management of Associations.” Governance responsibility is clearly assigned—“the head of Corporate External Affairs reports directly to the CEO”—and the company “actively represents [its] positions” both “independently” and “as members of national and international economic, industry, and specialist associations.” Moreover, Aurubis publicly affirms that it will “conduct [its] engagement activities in line with the goals of the Paris Agreement” and collaborates with bodies such as the “Association of German Industries (BDI)” and the “German Chemical Industry Association (VCI)” to develop “constructive contributions to the discussion and practical recommendations for action for an ambitious and sustainable energy and climate policy.” However, the company does not disclose a climate-specific mechanism to monitor or review lobbying activities, such as a dedicated climate-lobbying review, board sign-off on climate-advocacy plans, or formal criteria for assessing the climate alignment of its trade associations, indicating that the governance framework for lobbying does not clearly define and systematically manage climate-related lobbying oversight.	2