Kering SA

Lobbying Governance

AI Extracted Evidence Snippet Source

**9. a) What public decisions do you target through your lobbying activities? Please provide details for the** **last two years, focusing on lobbying related to human rights (including fundamental social rights), the** **climate and governance, for the main jurisdictions in which you carry out lobbying (including the EU, United** **States, emerging markets and other regions).** As part of its Sustainability Strategy, Kering stands behind a responsible approach to lobbying, intended to support public decision-making in a fully transparent way, while leaving the task of defining and deciding what does and does not fall within the public interest to public-sector officials. In the last two years, the only lobbying activities – as defined by France's High Authority for transparency in public life (HATVP) and the transparency register of the European Union – directly carried out by the Group have related to planning applications and applications regarding occupation of the public domain. The only lobbying expenses incurred by the Group has been via the industry associations of which the Group is a member. **b) How do you check and ensure alignment between your ESG targets and the positions of the trade bodies** **of which you are a member, and any potential divergence from your own positions? Do you publish a report** **in which you detail the ways in which your company's positions are aligned with those of your trade bodies,** **but also cases where they may differ?** Kering belongs to a limited number of industry associations, particularly in France, Italy and the United Kingdom. The Group decides whether to renew its membership each year based on its own priorities. By being a member of these associations, Kering aims to ensure that it is fully informed about changes in legislation and regulations (through Afep, Medef, Confidustria, etc.) and to keep up with the main issues in the Luxury industry (Comité Colbert, Altagamma, Walpole, etc.). Kering's contribution to these associations is aligned with the Group's CSR strategy and is intended to encourage the sustainable growth of the Luxury industry. We are particularly careful to ensure that Kering is not a member of any trade or industry association that may have positions that are controversial in regard to the public interest, or whose positions do not correspond with the rules established by the Group for its stakeholders. In practical terms, this means that Kering: - has an internal disclosure procedure, including each new membership being referred to the Group Compliance Department; - constantly monitors news relating to these organizations; - arranges for some of its head-office staff members take part in proposed collective initiatives; - ensures that people representing Kering in these associations can make a referral to the Compliance Department where they have doubts about an initiative or developments in a given situation. Kering complies fully with the rules established by the High Authority for transparency in public life (HATVP) in France, where the Group's head office is located, and by the transparency register of the European Union. Each Group employee, including the members of Kering's Executive Committee, comply with the requirements of its Code of Ethics, and Kering's contribution to these industry associations and any potential lobbying activity takes place in accordance with the principles established in that Code. **c) What resources (human and financial) do you allocate to your lobbying activities across all your markets** **around the world?** Kering's Chief Sustainability and Institutional Affairs Officer is a member of the Group's Executive Committee and reports directly to Kering's Chairman and CEO François-Henri Pinault. Any potential lobbying activity carried out by Kering's head office is done by three members of its Institutional Affairs department – where two work full-time on this subject and one on a part-time basis. Institutional meetings attended by these three staff members, and by the Group's Chairman and Executive Management, are disclosed internally and are subject to prior checks by Kering's Compliance department in order to avoid any risk of a conflict of interest. As stated above, in 2022, all resources used by the Group in relation to lobbying consisted of contributions to professional or industry associations (Camera Nazionale della Moda Italiana, Confindustria, Comité Colbert, etc.) that may have carried out lobbying activities. As stated in Kering's [2022 Universal Registration Document (p. 268), these contributions totaled €1,226,520 in](https://www.kering.com/assets/front/documents/KERING_DEU_2022_US.pdf) 2022. Of that sum, €269,775 can be attributed to lobbying activities, since the activities of these associations and federations are much broader than lobbying alone.

https://www.kering.com/assets/front/documents/Kering_Answers_Written%20questions_AGM_2023_27042023.pdf

**Additional information on Trade Associations**

Kering disclosed the trade associations which it is a member of, or engages with, which are likely to take a position on any policy, law or regulation that may impact the climate in its CDP 2023 answer, as specified below:

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In line with Kering's collaborative approach, the Group seeks to ensure that the most material sustainability topics identified are addressed by the industry associations and structures in which it plays an active role. For example, Kering:

- addresses matters relating to circularity, environmental labeling and product durability as part of work
done under the auspices of the Fédération de la Haute Couture et de la Mode (FHCM);

- contributes to the development of a responsible fashion industry, including the promotion of social
responsibility, as part of the Camera Nazionale della Moda Italiana;

- addresses topics related to the climate, oceans and biodiversity as part of the Fashion Pact, which was
launched as a mission given to Kering Chairman and CEO François-Henri Pinault by French President
Emmanuel Macron on the occasion of the G7 Summit in Biarritz in 2019.

Kering limits the number of trade associations of which it is a member. By being a member of these associations,
Kering aims to ensure that it is fully informed about changes in legislation and regulations (through Afep, Medef,
Confidustria, etc.) and to keep up with the main issues in the Luxury industry (Comité Colbert, Altagamma,
Walpole, etc.). Kering's contribution to those associations is intended to encourage the sustainable growth of the
Luxury industry and is aligned with the Group's sustainability approach.

If the Group were to find a material misalignment between the positions of an association of which it is part and
its own ESG objectives (for example, misalignment of the association's activities with the goals of the Paris
Agreement), it would (i) engage with the association concerned to achieve realignment with clear timelines, but if
that were unsuccessful, the Group would (ii) questions whether to leave the association. The Group grants itself
the option not to renew its membership each year, based on its own priorities or if the positions taken by the entities
diverge from its commitments, values, or ESG objectives. Such divergence has not yet been found to have occurred
as part of the monitoring done by Kering's employees and their participation in these associations.

https://www.kering.com/api/download-file/?path=Additional_information_to_Kering_ESG_reporting_2023_2024_dd84f31de0.pdf

#### GOVERNANCE FOR CLIMATE CHANGE & STRATEGY

The Sustainability Committee of Kering's Board of Directors oversees this Climate Strategy. Its role is to review the progress of ongoing projects and initiatives, along with the outcomes already achieved in terms of climate-related targets and goals. The Committee also supports the Group in establishing, implementing and monitoring good corporate governance, in line with:

- the aim of the Board of Directors and Executive Management to maintain a high level

of sustainability in economic, social and environmental terms;

- the Group's clear ambitions in terms of ethics;

- the corporate citizenship policies and practices (which include climate management)

to be upheld by the Group, its senior executives and employees.

Along with its progress reviews, the Committee also meets regularly to consider topics such as the Group's carbon offsetting approach, along with the transitional and physical risks related to climate change. The Chair of the Remuneration Committee sets and reviews, pursuant to the proposal put forth by the Sustainability Committee, the objectives for the Group's executive corporate officers in terms of non-financial targets. The annual variable remuneration and multi-annual variable remuneration for the Chairman and Chief Executive Officer and the Group Managing Director are partly linked to non-financial criteria. Specifically, sustainability accounts for 10% of the annual variable remuneration criteria, and biodiversity for 10% of the multi-annual remuneration criteria. [...] Kering's Sustainability Strategy, including its Climate Strategy as well as the related risks and opportunities for the business, is reviewed by the Board of Directors and its Sustainability Committee whose members include Kering's Chairman and CEO, François-Henri Pinault and the Group's Managing Director, Jean-François Palus.

In line with the Group's commitments in terms of climate action, the role of Climate Change Lead was created within the Board of Directors in 2022. In coordination with the Chair of the Sustainability Committee and the Lead Independent Director, the Climate Change Lead's role includes ensuring that climate issues are taken into account by the Board and that they are factored into all of the Group's decisions. Finally, the Climate Change Lead reports to the Board at least twice a year on the deployment of the Climate Strategy within the Group and on the implementation and results of the climate change mitigation and adaptation action plans. The duties of the Climate Change Lead are detailed in the Governance Chapter of Kering Universal Registration Document.

Together, the Board of Directors and the Sustainability Committee support the implementation of the Climate Strategy within the Group and its Houses, which put it into action every day under the guidance of dedicated experts and in consultation with a wide range of internal and external stakeholders.

Kering's Chief Sustainability and International Affairs Officer (CSO), a member of the Executive Committee and directly reporting to Kering's Chairman and CEO, is in charge of the definition and implementation of the Climate Strategy. The CSO identifies opportunities to present to the Sustainability Committee of the Board by combining sustainability expertise with a strategic sustainability vision and the priorities for risk mitigation.

https://www.kering.com/api/download-file/?path=KERING_Climate_Strategy_2023_b3f18dc6b4.pdf

**9.** **Do you publish a responsible lobbying* charter?** **Are you a member of professional associations that adopt positions on some matters that are** **controversial in regard to the public interest? If so, what action are you taking to make those** **associations change their position?** **Across your entire geographical scope, what human and financial resources do you allocate to** **lobbying?** *** "Lobbying is playing a growing role in public decision-making. The organizations concerned** **(companies, professional organizations, non-profits, public-sector bodies, etc.) spend a lot of time** **and money on lobbying. When conducted with integrity and when its use is made clear and** **transparent, lobbying can play a positive role and help give public-sector decision-makers** **information that is useful for them to consider. However, unregulated lobbying can give rise to** **abuses, the effect of which is that decisions are taken more in response to specific private-sector** **interests than the public interest." (Transparency International)** As part of its overall sustainability strategy, Kering agrees that a responsible approach to lobbying is needed, intended to support public decision-making in a fully transparent way, while leaving the task of defining and deciding what does and does not fall within the public interest to public-sector officials. Although it has not published any responsible lobbying charter to date, Kering complies fully with the requirements of its Code of Ethics in this matter, and with the rules established by the high authority for transparency in public life (HATVP) in France, where the Group's head office is located, and by the European Commission's transparency register. Any lobbying activity carried out by Kering is done by four members of its Institutional Affairs department (two of whom work full-time and two part-time). In 2021, they carried out no direct lobbying. Institutional meetings attended by those four staff members, and by the Group's Chairman and Executive Management, are disclosed internally and are subject to prior checks by Kering's Compliance department in order to avoid any risk of a conflict of interest. In 2021, all resources used by the Group in relation to lobbying consisted of contributions to professional or industry associations (Association Française des Entreprises Privées, British Fashion Council, Comité Colbert, etc.). In this area, we are particularly careful to ensure that Kering is not a member of any professional association that may have positions that are controversial in regard to the public interest. As stated in the 2021 Universal Registration Document (p. 255), these contributions totaled €1,503,318 in 2021. Of that sum, €272,000 can be attributed to lobbying activities, since the activities of these associations and federations are much broader than lobbying alone.

https://www.kering.com/assets/front/documents/Kering_Answers_Written_Questions_2022_AGM.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]One of the missions of the Sustainability Committee at Board level is to ensure that all direct and indirect activities that influence policy are consistent with Kering's overall climate change strategy. The Committee comprises six Directors, with a balance between independent directors and executive directors. The Committee has been particularly active in the definition of the Group 2025 sustainability strategy and the implementation of its science-based target for GHG emissions.
Moreover, Kering's Chief Sustainability Officer, member of the Executive Committee, who directly reports to Kering's chairman and CEO, is also Head of international institutional affairs. She is responsible for both the development of Kering's sustainability strategy and the direction of the Group's institutional affairs, therefore keeping direct and indirect policy influence activities in line with Group's sustainability strategy, including climate strategy.
In addition, since 2019, there is a lead independent Director at Board level. Alongside the typical duties associated with this position, acting as the Board's spokesperson vis- à- vis investors on environmental, social and governance (ESG) issues, in liaison with the Chairman. Lastly, coordination towards Kering's sustainability strategy, especially regarding climate change, is ensured through a network of managers dedicated to sustainability issues in each Brands. The Sustainability Leads meet regularly to coordinate and determine the pace of implementation of the sustainability strategy, including climate change mitigation, and to draw up action plans to deal with cross-company issues within the Group, as well as more specific issues affecting individual brands.

CDP Questionnaire Response 2022

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]One of the missions of the Sustainability Committee at Board level is to ensure that all direct and indirect activities that influence policy are consistent with Kering's overall climate change strategy. The Committee comprises six Directors, with a balance between independent directors and executive directors. The Committee has been particularly active in the definition of the Group 2025 sustainability strategy and the implementation of its science-based target for GHG emissions.

CDP Questionnaire Response 2023

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023