Bouygues SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Bouygues SA provides extensive, concrete disclosure of its climate-policy lobbying. It names numerous specific measures it has engaged on – including the EU “Fit for 55” legislative package, France’s “Loi AGEC”, “Loi Climat et Résilience”, the “E+C-” regulatory framework, RT 2012 and RBR 2020 building regulations, the EU Commission’s EeB PPP, SCC EIP and SET Plan programmes, and the French working group on environmental labelling – clearly identifying the jurisdiction and subject matter for each. The company also describes a variety of direct and indirect mechanisms and the targets of those efforts: participation in ADEME- and ARCEP-led technical working groups, representing the EGFPTB in consultations with the French Environment Ministry’s housing department, “discussions and meetings with persons involved in the project”, “regular correspondence”, collaboration with the EU Commission through public-private partnerships, membership of The Shift Project, and the signing of the Decarbonize Europe Manifesto that appeals to “the French government and European countries”. Finally, Bouygues is explicit about the concrete outcomes it seeks, such as “defin[ing] thresholds for a regulatory environmental label” for future RBR 2020 rules, setting “carbon performance thresholds and calculation methods” under the E+C- framework, extending BBC low-energy building standards, creating rules for “calculating the environmental impact of data consumption by telecom operators”, and driving Net-Zero Energy districts across the EU, all of which it says are “aligned with the Paris Agreement” and supported “with no exceptions”. This level of detail on policies, mechanisms and desired results demonstrates comprehensive transparency in the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Bouygues SA has established governance structures that connect its European advocacy with its climate strategy, but it provides limited detail on the mechanisms for reviewing or approving its lobbying positions against climate goals. For example, “Bouygues Europe works for both Bouygues SA and its business segments … advising them and representing them in the European institutions,” and said that “Represetant of Bouygues Europe are member of the Climate Strategy Commitee at a group level,” indicating that policy engagement is linked to climate oversight. The Group Climate Strategy and Biodiversity Committee “is chaired by Edward Bouygues, Deputy CEO of the Group, and brings together Sustainable Development Directors tasked with monitoring the application of the roadmap,” showing a named formal body responsible for high-level climate governance. Bouygues also reports that “the Bouygues’ Group supports some initiatives and organizations that could influence policy, law or regulation that may impact the climate” and confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes.” However, the company does not disclose any specific policy or process for approving or auditing its direct or indirect lobbying, nor describe criteria for assessing alignment with its climate commitments or conducting regular reviews of its trade association memberships. We found no evidence of a defined climate-lobbying review procedure or a publicly available audit evaluating consistency between its advocacy activities and its climate targets.	2