Orange SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Orange SA has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly identified specific climate policies it has engaged with, such as the ITU Recommendations L.1023, L.1470, and L.1450, as well as France's Law n° 2021-1755 and the earlier REEN law. These policies focus on decarbonization, circular economy principles, and reducing the environmental footprint of digital technology. Additionally, Orange has disclosed its active participation in the development of international standards and regulations through mechanisms such as leadership roles in the ITU-T Study Group on environmental recommendations, participation in European Commission pilot programs, and collaboration with organizations like ETSI and the GHG Protocol. The company has also detailed its involvement in ARCEP's working group and the European Green Digital Coalition. These disclosures provide clear details about both the mechanisms and the policymaking targets, such as the ITU, European Commission, and ARCEP. Furthermore, Orange has been transparent about the specific outcomes it seeks, including contributing to the decarbonization of the telecommunication sector, improving energy efficiency, and aligning with the Paris Agreement's 1.5°C target. The company's efforts to develop methodologies for assessing ICT sector emissions and its support for laws aimed at environmental regulation in the digital sector further highlight its commitment to achieving measurable climate-related outcomes. This level of detail and clarity illustrates Orange's comprehensive approach to disclosing its climate lobbying efforts and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Orange Group has established a defined governance process to ensure alignment of its climate lobbying activities with its overall climate change strategy. "The Executive Committee of Orange Group supervises the coherence and the consistency between the Climate Change Strategy of Orange and the different engagements influencing policy," demonstrating oversight by a high-level governing body. The Executive Committee also "reviews and validates the detailed strategies elaborated by the different business divisions and geographies" and "ensures regular review of the climate change action plans and performance results, through internal indicators," highlighting robust monitoring mechanisms. Additionally, the Environmental division at the Group level "defines, coordinates, and regularly monitors its engagement activities to ensure the consistency with the overall climate change strategy," further evidencing structured governance. The evidence also addresses indirect lobbying efforts, stating that "the main engagements of the Orange Group, namely its activities within the GSMA (Global System for Mobile Communications), the ITU (International Telecommunication Union), the EC (European Commission) and the JAC (Joint Alliance for CSR) is supervised by the Environmental division and closely followed by executive committee," indicating alignment of both direct and indirect lobbying activities with the company's climate strategy. This indicates strong governance with clear monitoring details and responsible parties identified.	3