Telekom Austria AG

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited Telekom Austria AG provides only limited insight into its climate-related lobbying. It identifies one specific policy focus—the European Green Deal—and notes its founding membership in the European Green Digital Coalition, signalling an intention to “actively shape” that overarching EU initiative, but it does not list any other legislation or regulations it seeks to influence. The company names the European Commission and European Parliament as the primary policymaking bodies it engages, yet it offers no detail on how it approaches them (for example, meetings, letters, consultations, or participation in hearings). Finally, while the disclosures describe broad aspirations such as achieving climate neutrality by 2050 and supporting the EU’s green and digital transition, they do not articulate concrete policy changes, amendments, or measurable targets the company is pursuing through its advocacy. Together, this leaves a partial picture of its lobbying activities, with basic references to the policy area and targets but little clarity on tactics or specific outcomes sought. 1
Lobbying Governance
Overall Assessment Comment Score
Moderate Telekom Austria discloses several elements that indicate a structured, though still limited, governance approach for overseeing lobbying and ensuring it aligns with its climate ambitions. The company states that “special procedures as well as approval and reporting requirements are defined for … lobbying in the A1 Group Guidelines Anti-Bribery, Anti-Corruption & Conflict of Interest,” and that the same policy “contains a strict ban on all forms of bribery and corruption as well as detailed regulations on … lobbying,” showing that lobbying activities are subject to formal internal controls. Oversight responsibilities are clearly assigned: the Group Compliance Director “berichtet direkt an den A1 Group Vorstand und den A1 Group Aufsichtsrat” and is “befugt … Audits zur Überprüfung der Wirksamkeit des CMS” including areas covered by the lobbying rules, while the A1 Group Board “legt die Compliance Politik und Compliance Strategie fest,” demonstrating a defined escalation and review structure. In relation to climate-specific engagement, the company explains that “as the board member who is responsible for sustainability and ESG, Group CEO stands behind the commitments … Together with the Sustainability Manager, Group CEO confirms the proposed direction and ensures future steering is aligned with the approved climate change strategy and our climate commitments,” and it publicly commits to conducting engagement “in line with the goals of the Paris Agreement.” These statements evidence a process and named senior accountability for aligning external engagement with climate strategy. However, the disclosures do not specify how the company monitors the climate-policy positions of trade associations, whether it assesses or corrects misaligned indirect lobbying, or whether the CMS audits explicitly test climate-lobbying alignment; the evidence focuses on broad compliance and anti-corruption controls rather than a dedicated climate-lobbying review. Therefore, while the presence of formal policies, annual risk assessments, and clear executive oversight suggests moderate governance, the absence of detailed monitoring criteria for both direct and indirect climate lobbying and of any published alignment review limits the overall strength of the framework. 2