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VZ Holding AG has established extensive governance structures for ESG and climate issues, with the Board of Directors’ Risk, Sustainability & Audit Committee assuming “responsibility for all sustainability issues” and an Executive Board sustainability officer alongside a Sustainability Committee that “meets at least once a month.” That committee, chaired by Manuel Rütsche, and the RSAC, which “usually meets four times each year,” focus on “assessing the functioning and effectiveness of the internal control system (ICS) and risk management, in particular with regard to climate-related risks” and “monitoring progress towards achieving climate targets” through net zero target reviews and transition plan reporting. However, we found no evidence of any policy, process or oversight mechanism to govern the company’s direct or indirect lobbying activities or to align lobbying with its climate objectives: the disclosures make no reference to how lobbying is monitored or managed, how alignment is enforced, or who, if anyone, oversees such advocacy efforts. Consequently, there is no indication that VZ Holding AG maintains a lobbying governance framework.
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