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| Overall Assessment |
Comment |
Score |
| Strong |
Merck KGaA provides a high degree of transparency around the specific climate policies it lobbies and the outcomes it seeks, while offering more limited detail on its lobbying processes. It clearly identifies a broad set of individual measures, including the EU Emission Trading Scheme (EU ETS), the Carbon Border Adjustment Mechanism (CBAM), the EU Green Deal, the ECHA PFAS restriction proposal, PFAS legislation in the US, the Urban Waste Water Directive, EU electricity market design, the Green Deal Industrial Plan, the Net Zero Industry Act, and various Free Trade Agreements. In contrast, the company reports only that it holds “personal meetings with policy-makers” and works through industry bodies such as the European Chemical Industry Council (CEFIC) and the German Chemical Industry Association (VCI), without naming additional engagement methods or specifying individual target entities. It is, however, explicit about the outcomes it seeks: advocating for “the allocation of ETS certificates to reflect the real situation,” ensuring “a reasonable (though ambitious) reduction of certificates in a level-playing field,” and proposing to exclude the chemical industry from CBAM, all while aligning its positions with the objectives of the Paris Agreement.
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3
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| Overall Assessment |
Comment |
Score |
| Moderate |
Merck KGaA provides some insight into how it keeps its policy engagement aligned with its climate agenda, stating that "Merck’s engagement activities are mainly driven by our Group function Corporate Affairs" and that this unit is "well aware of Merck’s overall position on climate change" and shares that position internally through "intranet, webinars, townhall meetings of the Board." The company also affirms a top-level commitment by answering "Yes" when asked whether it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement", and it explains that employees who lobby are "often deeply involved in our climate action program as well. By this, consistency between Merck's strategy and our advocacy activities is ensured." These statements outline a mechanism – the Corporate Affairs function – that is responsible for coordinating and aligning engagement, and they describe an internal process for ensuring consistency between climate strategy and advocacy. However, the disclosure does not describe a formal review timetable, auditing methodology, or escalation procedure for misalignment, and no evidence is provided of systematic monitoring of trade-association positions beyond noting that "we actively participate … through our work with industry coalitions." The company does not disclose board-level or named senior-executive oversight of lobbying alignment, nor does it report any actions taken to address or withdraw from associations with conflicting positions. Overall, this indicates a moderate level of governance, with a stated process and responsible function but limited detail on monitoring, accountability, and indirect-lobbying alignment.
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2
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