Capgemini SE

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate Capgemini provides only limited insight into which climate-related rules it actually seeks to influence. The disclosures name one identifiable policy engagement – its response to Ofgem’s “Future Systems and Network Regulation” open letter – while other references (such as the SEC climate-disclosure proposals or the EU Deforestation Regulation) are described only in analytical terms, so the list of policies lobbied remains far from complete. The company does, however, reveal two distinct ways it tries to shape public policy: it “responded to Ofgem’s open letter” and it joined a multi-company “joint letter to European heads of state” calling for higher 2050 emissions-reduction targets, thereby identifying both the consultation process and letter-writing as mechanisms and naming Ofgem and national leaders as the targets. On the substance of what it wants, Capgemini Invent sets out a detailed agenda in the energy-network consultation, advocating “whole-system coordination”, “regional network control”, “significant upgrades to the electricity network”, and the adoption of “open data” to accelerate decarbonisation, giving a clear picture of the outcomes it seeks. Outside this UK energy-network filing, the company’s stated ambitions remain high-level and aspirational. Overall, Capgemini offers a moderate level of transparency: it clearly states the policy changes it is pressing for in one domain and discloses some of the channels it uses, but it does not systematically list all the climate policies it lobbies or describe its engagement methods across jurisdictions. 2
Lobbying Governance
Overall Assessment Comment Score
Moderate Capgemini SE has embedded climate considerations in its engagement governance by stipulating that “all lobbying or direct support of political policies must be signed of by a member of the Group Executive Board (GEB)” and that “support of various communiqués is subject to agreement of our CEO,” who “as a member of the net zero board has a clear understanding of our overall climate change strategy.” Strategic oversight is provided at the highest level, with the Group CEO “overall responsible for material decisions relating to our climate change strategy,” supported by its Group Executive Committee and a dedicated Group net zero board, and these requirements are integrated into its Code of Business Ethics and “Blue Book” policies and training. However, the company does not disclose any process for aligning indirect lobbying through trade bodies, and we found no evidence of a formal audit or recurring monitoring procedure specifically for climate-related lobbying activities. 2