Orange SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Orange SA has implemented a structured governance process to ensure its policy engagement is aligned with its climate objectives, with the Executive Committee of Orange Group explicitly tasked with supervising the coherence and the consistency between the Climate Change Strategy of Orange and the different engagements influencing policy. The Committee reviews and validates the detailed strategies elaborated by the different business divisions and geographies and ensures continued performance by tracking climate change action plans through internal indicators. Oversight is further embedded in an Environmental division that defines, coordinates, and regularly monitors its engagement activities to ensure the consistency with the overall climate change strategy, including through preparatory steering committees on scope 3 trajectories and other environmental subjects. This governance extends to indirect lobbying via industry bodies, as the main engagements of the Orange Group, namely its activities within the GSMA, the ITU, the EC and the JAC are supervised by the Environmental division and closely followed by executive committee. It has also stated that it has engaged two trade associations, "European Telecommunications Network Operators Association (ETNO)" and "European Telecommunications Standards Institute (ETSI)" stating that they attempted to influence their positions and "they have changed their position", suggesting action to align its trade associations with its climate values. Orange has also made a public commitment to conduct its engagement activities in line with the goals of the Paris Agreement. While this framework clearly identifies formal bodies responsible for alignment and sets out regular review processes, the company does not disclose a dedicated review of direct lobbying activities or an independent audit of its climate?lobbying alignment. View Sources	B

Overall Assessment

Analysis

Score

Strong

Orange SA has implemented a structured governance process to ensure its policy engagement is aligned with its climate objectives, with the Executive Committee of Orange Group explicitly tasked with supervising the coherence and the consistency between the Climate Change Strategy of Orange and the different engagements influencing policy. The Committee reviews and validates the detailed strategies elaborated by the different business divisions and geographies and ensures continued performance by tracking climate change action plans through internal indicators. Oversight is further embedded in an Environmental division that defines, coordinates, and regularly monitors its engagement activities to ensure the consistency with the overall climate change strategy, including through preparatory steering committees on scope 3 trajectories and other environmental subjects. This governance extends to indirect lobbying via industry bodies, as the main engagements of the Orange Group, namely its activities within the GSMA, the ITU, the EC and the JAC are supervised by the Environmental division and closely followed by executive committee. It has also stated that it has engaged two trade associations, "European Telecommunications Network Operators Association (ETNO)" and "European Telecommunications Standards Institute (ETSI)" stating that they attempted to influence their positions and "they have changed their position", suggesting action to align its trade associations with its climate values. Orange has also made a public commitment to conduct its engagement activities in line with the goals of the Paris Agreement. While this framework clearly identifies formal bodies responsible for alignment and sets out regular review processes, the company does not disclose a dedicated review of direct lobbying activities or an independent audit of its climate?lobbying alignment.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Orange SA offers a highly transparent picture of its climate-policy lobbying. It names a wide range of specific measures it has worked on, including ITU Recommendations L.1480, L.1470, L.1450, L.1023 and the related L.1410–L.1440 series, France’s Law n° 2021-1755 of 23 December 2021 and the earlier REEN law, as well as European Commission initiatives such as the DG CONNECT pilot programme and the 2009 Recommendation on mobilising ICT for a low-carbon economy. The company also spells out how it engages: it holds “Chairmanship, Vice-Chairmanship [and] Co-Rapporteur” positions in ITU-T Study Group 5, leads the European Green Digital Coalition’s “Avoided Emissions” working group, sits on ARCEP’s Committee of Digital and Environmental Experts, participates in DG CONNECT pilot tests, and attends ITU symposia—thereby clearly identifying both its mechanisms and its targets (ITU, European Commission, ARCEP, ETSI, IEC, GSMA and others). Finally, Orange is explicit about what it wants to achieve, aiming for “the decarbonization of telecommunication sectors”, the development of 1.5 °C emissions trajectories for ICT, the “implementation of circular economy principles in the sector”, inclusion of environmental-footprint reporting in French regulation, and broader energy-efficiency standards across the EU. By describing the concrete policies, the exact channels of influence and the specific outcomes it seeks, Orange provides a comprehensive and detailed account of its climate-related lobbying activities.	A