Nestle SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Nestl discloses a highly structured and transparent process to govern and audit its climate-related lobbying. It welcomes the development of the Global Standard on Climate Responsible Lobbying and use[s] it to guide our annual Nestl Climate Advocacy Industry Associations Review disclosure, which publicly sets out Nestl S.A.s main industry association memberships and an assessment of how far their positions are aligned with the objectives of the Paris Agreement, thereby functioning as a dedicated climate-lobbying alignment report. Governance spans both direct and indirect channels: the company provide[s] specific guidance to our local market teams on aligning advocacy and external engagement activities with the goals of the Paris Agreement and, for trade associations, operates a clear misalignment protocolIf we identify a misalignment with an industry association position Nestl can implement a clear public statement request the industry association refrains from engaging on mis-aligned issues; and/or suspension or discontinuation of membership. Oversight is explicitly assigned: The Executive Vice President General Counsel, Corporate Governance and Compliance and the Deputy Executive Vice President Chief Communications Officer co-own this policy and formally approve this Nestl Climate Policy Engagement Review, while Climate advocacy is part of the scope of the ESG & Sustainability Council supported by an internal Advocacy Coordination Group. This Council includes ten Executive Board members and reports monthly to the full Executive Board, ensuring senior-level monitoring. The company also references external benchmarking, noting that its policies are assessed by the Access to Nutrition Initiative (ATNI), against the Responsible Lobbying Framework, adding an additional layer of scrutiny. Collectively, the published review, detailed policy and escalation steps, and named Board-level oversight bodies indicate a comprehensive governance system for ensuring that both its own lobbying and that of its industry associations remain aligned with its Paris-aligned climate objectives, with no significant gaps in disclosure identified. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Nestl discloses a highly structured and transparent process to govern and audit its climate-related lobbying. It welcomes the development of the Global Standard on Climate Responsible Lobbying and use[s] it to guide our annual Nestl Climate Advocacy Industry Associations Review disclosure, which publicly sets out Nestl S.A.s main industry association memberships and an assessment of how far their positions are aligned with the objectives of the Paris Agreement, thereby functioning as a dedicated climate-lobbying alignment report. Governance spans both direct and indirect channels: the company provide[s] specific guidance to our local market teams on aligning advocacy and external engagement activities with the goals of the Paris Agreement and, for trade associations, operates a clear misalignment protocolIf we identify a misalignment with an industry association position Nestl can implement a clear public statement request the industry association refrains from engaging on mis-aligned issues; and/or suspension or discontinuation of membership. Oversight is explicitly assigned: The Executive Vice President General Counsel, Corporate Governance and Compliance and the Deputy Executive Vice President Chief Communications Officer co-own this policy and formally approve this Nestl Climate Policy Engagement Review, while Climate advocacy is part of the scope of the ESG & Sustainability Council supported by an internal Advocacy Coordination Group. This Council includes ten Executive Board members and reports monthly to the full Executive Board, ensuring senior-level monitoring. The company also references external benchmarking, noting that its policies are assessed by the Access to Nutrition Initiative (ATNI), against the Responsible Lobbying Framework, adding an additional layer of scrutiny. Collectively, the published review, detailed policy and escalation steps, and named Board-level oversight bodies indicate a comprehensive governance system for ensuring that both its own lobbying and that of its industry associations remain aligned with its Paris-aligned climate objectives, with no significant gaps in disclosure identified.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Nestlé publicly discloses extensive detail on every dimension of its climate-policy advocacy. It names a wide array of specific measures it has engaged on, including the “United States Farm Bill,” the “United States Inflation Reduction Act,” the “Advanced Clean Trucks rule” adopted by several U.S. states, the “North Carolina Carbon Plan,” the “EU regulation on deforestation-free products,” and the “EU Product Environmental Footprint Proposal,” as well as global processes such as stronger Nationally Determined Contributions under the UNFCCC and biodiversity disclosure rules negotiated at CBD COP15. The company also spells out how it engages: it “supported Ceres Farm Bill Priorities which were sent to the U.S. Congress,” “signed letters to U.S. Governors” backing the truck rule, met “directly with government representatives during the CBD COP15 negotiations,” joined coalitions like BICEP and FoodDrinkEurope, and participated in EU public consultations and working groups with the European Commission—clearly identifying both the instruments (letters, meetings, coalition statements, official delegations) and their specific targets (U.S. Congress, state legislatures, European Commission, UN bodies). Finally, Nestlé is explicit about what it wants these policies to deliver, advocating for “improved technical assistance, conservation programs, enhanced market development opportunities for farmers,” a swift passage of the Inflation Reduction Act to unlock “$369 billion in Energy Security and Climate Change programs,” phasing out unabated fossil fuels, accelerating zero-emission vehicle deployment, and requiring supply-chain transparency to “halt and reverse the loss of nature by 2030.” This level of specificity across policies, mechanisms, and desired outcomes demonstrates comprehensive transparency in the company’s climate-related lobbying disclosures.	A