Accor SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Accor discloses comprehensive detail on its climate-related lobbying. It names the specific measures it engages on, including "Décret Tertiaire (France)", the "European directive for eco-efficient buildings", and "Loi Climat et Résilience (France)", as well as other regulations such as the "Loi anti-gaspillage pour une économie circulaire (France)" and standards like the BBCA label for low-carbon buildings. The company also spells out its methods—engaging in "consultation meetings requested by policy makers (e.g. French Ministry)" and collaborating with ADEME and European Union institutions—while also working through industry groups like the Sustainable Hospitality Alliance and participating in initiatives such as the ACT project. Finally, it is explicit about the outcomes it seeks, from advocating that public authorities introduce more ambitious commitments and technical support beyond legal requirements, to calling for stricter energy-efficiency standards, the removal of single-use plastics, and endorsing the Glasgow Declaration on Climate Action in Tourism, committing to halve emissions by 2030 and achieve net zero by 2050. This level of detail demonstrates a high degree of transparency in Accor’s climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Accor SA has established clear oversight for its direct lobbying activities, noting that “the person in charge of Accor’s responsible lobbying is the Chief Sustainability Officer who is also in charge of the operational monitoring of the sustainability strategy PLANET 21” and that this officer “ensures consistency between the external engagement and Accor’s strategy.” The company explains that “tools and processes are designed at global headquarters and then deployed in the hotels” so that every action aligns with its global climate commitments. In addition, the Appointments, Compensation and CSR Committee and the Ethics, Compliance and Sustainable Development Committee review CSR policy guidelines, and the Carbon Steering Committee plus its Project Management Office drive carbon‐strategy implementation. However, Accor does not disclose any processes for governing indirect lobbying through trade or industry associations, and there is no publicly available audit or third‐party review evaluating how its climate‐related lobbying aligns with its stated objectives.	2