Cemex SAB de CV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Cemex discloses several mechanisms aimed at keeping its climate-related advocacy activities on track with its net-zero strategy, yet the information falls short of a fully detailed, board-supervised system. The company states that It is in our best interest that the trade associations of which we are members align with the Paris Agreement and with our climate action advocacy goals and climate policy positions, and explains that it is conducting a comprehensive trade association climate advocacy review to assess the alignment of the associations we collaborate with regarding our climate and environmental objectives. The review covers 17 key associations, applies criteria such as Paris Agreement and the Net-Zero Agenda and Emissions Trading Systems, and is executed through an independent analysis of publicly available information and a survey sent to the trade associations, with results validated by the global sustainability team. Cemex further commited that if realignment fails, Cemex will evaluate separating itself from the association in question or ultimately dissolve its membership. During its 2024 review CEMEX concluded it was aligned with all its associations climate lobbying and thereby no action is needed, "We found no major misalignments between the trade associations climate policy positions and our own policy positions. Of the 14 associations evaluated, we found 12 were completely aligned with the Paris Agreement and Cemexs climate policy positions. The remaining two associations lacked a formal position in some of the advocacy priorities either due to the activities not being applicable, or the topic not being present in a national debate." Oversight is indicated at multiple levels: Through its Sustainability, Climate Action, Social Impact and Diversity Committee, the Board of Directors oversees and discusses in detail the climate-related risks and opportunities, while a dedicated CO2 Regulation Focus Group shares the insights from this collaboration with governments on a quarterly basis. The company also declares, Cemex is committed to lobbying and advocating for public policies and regulations in line with the goals of the Paris Agreement, signalling intent to align its direct engagement. However, we found no evidence that the board or another named body formally reviews or signs off on the alignment of individual lobbying positions. Likewise, the disclosures give limited detail on how direct lobbying activities are monitored beyond the focus groups information-sharing. This indicates a moderate level of governancestronger for trade-association oversight, but with incomplete transparency and formal oversight of direct lobbying alignment. View Sources	B

Overall Assessment

Analysis

Score

Strong

Cemex discloses several mechanisms aimed at keeping its climate-related advocacy activities on track with its net-zero strategy, yet the information falls short of a fully detailed, board-supervised system. The company states that It is in our best interest that the trade associations of which we are members align with the Paris Agreement and with our climate action advocacy goals and climate policy positions, and explains that it is conducting a comprehensive trade association climate advocacy review to assess the alignment of the associations we collaborate with regarding our climate and environmental objectives. The review covers 17 key associations, applies criteria such as Paris Agreement and the Net-Zero Agenda and Emissions Trading Systems, and is executed through an independent analysis of publicly available information and a survey sent to the trade associations, with results validated by the global sustainability team. Cemex further commited that if realignment fails, Cemex will evaluate separating itself from the association in question or ultimately dissolve its membership. During its 2024 review CEMEX concluded it was aligned with all its associations climate lobbying and thereby no action is needed, "We found no major misalignments between the trade associations climate policy positions and our own policy positions. Of the 14 associations evaluated, we found 12 were completely aligned with the Paris Agreement and Cemexs climate policy positions. The remaining two associations lacked a formal position in some of the advocacy priorities either due to the activities not being applicable, or the topic not being present in a national debate." Oversight is indicated at multiple levels: Through its Sustainability, Climate Action, Social Impact and Diversity Committee, the Board of Directors oversees and discusses in detail the climate-related risks and opportunities, while a dedicated CO2 Regulation Focus Group shares the insights from this collaboration with governments on a quarterly basis. The company also declares, Cemex is committed to lobbying and advocating for public policies and regulations in line with the goals of the Paris Agreement, signalling intent to align its direct engagement. However, we found no evidence that the board or another named body formally reviews or signs off on the alignment of individual lobbying positions. Likewise, the disclosures give limited detail on how direct lobbying activities are monitored beyond the focus groups information-sharing. This indicates a moderate level of governancestronger for trade-association oversight, but with incomplete transparency and formal oversight of direct lobbying alignment.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Cemex provides an unusually detailed picture of its climate-policy advocacy. It names a wide range of concrete measures it has worked on, including the European Union Emissions Trading System (including Phase IV discussions), the California Cap-and-Trade scheme, Mexico’s pilot ETS and subsequent revisions, carbon-tax regimes in Colombia, Mexico and Poland, the U.S. Water Resources Development Act, and specific CCS-related legislation. The company sets out how it engages: it holds “direct dialogue with state and federal officials,” meets EU Commission directorates such as DG CLIMA and DG GROW, participates in formal public consultations, and channels advocacy through industry bodies such as CEMBUREAU, GCCA, CANACEM and the Portland Cement Association, as well as an internal “CO₂ Regulation Focus Group” that coordinates outreach. It also identifies the targets of those approaches, citing EU Parliamentarians, the Permanent Representations of Member States including the UK, Poland, Croatia, Latvia and Spain, and national authorities revising Mexico’s ETS. Cemex is equally explicit about the results it seeks: for example, it urges that “resilient construction principles [be] infused into policy of WRDA and all federally funded public infrastructure and housing programs,” calls for “compensation for increased power prices in trade-exposed sectors,” favours a border carbon-adjustment mechanism that will “minimize leakage,” asks that carbon-pricing benchmarks be updated with real data and that the EU Innovation Fund support CCS and CCU, and seeks “policy support and financing for RD&D into CCS” together with clear deployment rules. This breadth of information on the policies addressed, the channels and counterparts used, and the specific legislative changes pursued demonstrates a comprehensive level of transparency around Cemex’s climate-related lobbying activities.	A