Delivery Hero SE

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Delivery Hero provides a reasonably clear picture of its climate-related lobbying. The company identifies one concrete policy focus—the review of the EU Packaging and Packaging Waste Regulation (PPWR)—and explains that it addressed broader themes such as “carbon neutrality and full environmental sustainability of material impacts,” but no other specific laws are named. Its description of how it lobbies is more detailed: the company “shared the Statement of Principles with various political stakeholders at the EU-level and meetings were organized as a follow-up,” it “regularly holds meetings with policy stakeholders,” and it also works indirectly through the industry body Delivery Platforms Europe, all aimed at EU policymakers. Delivery Hero is similarly explicit about what it wants from the PPWR process, stating, for example, “We believe that given the challenges associated with re-use of packaging, refill and waste hierarchy, Member States should incentivise such schemes and partner with industry to ensure their practical viability,” and calling for clarifications to the draft text to better reflect the role of delivery platforms. Together, these disclosures show moderate transparency on policy positions and strong clarity on mechanisms and targets, even though the company references only a single named climate policy.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Delivery Hero SE’s governance process for climate-related lobbying is centered on direct engagement oversight but lacks coverage of indirect channels and individual accountability. The company states that “we have a dedicated team that engages with policy makers on various topics” and that “all efforts are overseen by the Public Affairs team at our headquarters,” demonstrating a clear oversight structure. It adds that “the CSR & Sustainability team and the Public Affairs team at Central regularly meet in order to update each other among others on the climate action strategy as well as policy developments in the relevant regions,” illustrating an established process to align lobbying with its CSR & Sustainability strategy. However, the company does not disclose any mechanism for managing indirect lobbying through trade associations, nor does it name a specific individual responsible for overseeing lobbying alignment.	2