H & M Hennes & Mauritz AB

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	H & M Hennes & Mauritz AB provides a highly detailed and wide-ranging picture of its climate-policy lobbying. It names numerous individual measures across multiple jurisdictions – for example MEMR Regulation No.1/2015 on off-site PPAs in Indonesia, the EU Ecodesign for Sustainable Products Regulation, India’s Green Open Access Rules 2022, China’s Green Electricity (Corporate PPA) rules, the EU Renewable Energy and Energy Efficiency Directives, National Solar Roadmap 2041 in Bangladesh and many more – demonstrating full transparency about the public policies it tries to influence. The company also explains exactly how it engages and with whom: it sends “position papers to key MEPs in charge of the file in the European Parliament”, holds “1:1 meetings with policy makers”, organises supplier workshops with Bangladesh’s energy ministry, meets China’s NDRC, works through platforms such as the UNFCCC Fashion Charter and WWF, and contributes to formal EU consultations, thereby describing several concrete mechanisms and clearly identifying target institutions from EU legislators to state governments in Karnataka and Bangladesh. Finally, H&M spells out the concrete outcomes it seeks, such as “enable possibility for private offtaker to sign PPA” in Indonesia, advocating “for an ambitious 2030 renewable energy target” in the EU RED, calling for a 20 % energy-efficiency target in the EED, reducing Turkey’s energy-efficiency incentive threshold to “250 TEP”, strengthening mandatory biodiversity disclosure under COP15 Target 15, and removing solar-capacity limits in Indonesia. This breadth of named policies, specific engagement methods and clearly stated desired legislative changes reflects a comprehensive level of transparency on the company’s climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	H&M Hennes & Mauritz AB demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate change. The company discloses that "implementation of this policy and supporting strategies is the responsibility of the Head of Sustainability together with the Executive Management team," and accountability is integrated into respective business functions and brands, supported by a team of experts in the Group Sustainability Department. Additionally, the public affairs team collaborates closely with the team responsible for the overall climate strategy, ensuring alignment with climate goals and working on the basis of emissions data for Scope 1, 2, and 3. The company also states that it has a public commitment to conduct engagement activities in line with the goals of the Paris Agreement. However, while H&M engages with policymakers and international institutions to influence legislation and advocates for systemic change, there is no explicit evidence of a detailed process for monitoring or managing lobbying alignment, nor is there a publicly disclosed report or audit evaluating the alignment of its lobbying activities with climate goals. Furthermore, while the Head of Sustainability and executive management oversee implementation, the governance framework does not clearly address indirect lobbying through trade associations or provide detailed mechanisms for ensuring alignment across all lobbying channels. This indicates some governance measures are in place, but the disclosures lack comprehensive detail on monitoring processes and indirect lobbying alignment.	2