Henkel AG & Co KGaA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Henkel provides a mixed picture on climate-policy lobbying transparency. It clearly identifies one concrete policy forum it is trying to influence—the treatment of renewable carbon feedstocks in the Greenhouse Gas Protocol—explaining that its advocacy centres on the “Accountability of renewable carbon feedstocks and market-based mechanisms for the chemical industry.” However, beyond noting that upcoming EU Packaging & Packaging Waste Regulation (PPWR) rules will affect its products, the company does not indicate any direct attempt to shape that piece of legislation or any other climate-related law, so the range of disclosed policies is limited. On how it lobbies, Henkel describes analysing shortcomings in the existing GHG Protocol and putting forward detailed alternative approaches, which shows that it is actively submitting technical proposals, yet it does not spell out the channels used (such as consultation responses, meetings, or trade-association engagement) or name specific decision-making bodies or officials it targets, leaving the mechanism only partially transparent. By contrast, the company is very explicit about the outcomes it is seeking. It states that “mass balance must be site-specific,” “no multi-site credit transfer,” and that “mass balance must be certified under a mass balance scheme,” arguing that these changes would lower infrastructure costs and support its net-zero pathway. These detailed positions, each linked to the desired revision of the GHG Protocol, demonstrate a clear articulation of policy goals. Taken together, Henkel’s disclosures give a moderately detailed view of the substance and objectives of one significant lobbying effort, but offer far less insight into the breadth of policies it engages on or the practical mechanics of its advocacy.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Henkel provides some insight into how it governs the alignment of its climate-related engagement activities, noting that “our sustainability council plays the central role to perform coordination, initiative and control functions in relation to sustainability issues” and that this committee is “made up of managers from all business units and functions.” The disclosure outlines a process whereby “corporate functions support the implementation of our sustainability strategy… such as leveraging external stakeholder engagement,” while regional managers “develop and steer local engagement projects based on Henkel’s sustainability strategy,” indicating an internal mechanism for monitoring direct engagement. For indirect advocacy through industry bodies, Henkel states that “new engagement activities could be triggered in cases of potential unalignment on our sustainability targets with the associations we are a member of,” showing that it assesses and, where necessary, responds to misalignment with trade associations. The company also declares a public commitment to conduct its engagement “in line with the goals of the Paris Agreement.” However, Henkel does not disclose how frequently the sustainability council reviews lobbying positions, provide details of any dedicated climate-lobbying audit, nor explicitly confirm that direct lobbying of policymakers is systematically checked for alignment, so the breadth and formality of the governance process remain only moderately clear.	2