Heidelberg Materials AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Heidelberg Materials describes a well-defined, publicly reported system for keeping both its direct and trade-association lobbying on climate issues aligned with its own net-zero strategy. The company states that its "Group Climate Policy is binding and applicable company-wide aimed at guiding all our advocacy activities," and it supplements the policy with three public affairs offices to enable "direct exchange with political decision makers." Oversight is clearly assigned: "The alignment of trade associations with goals of the Paris Agreement is quarterly reviewed with the Chief Sustainability Officer (CSO) and the board member responsible for associations," and these senior leaders "supervised the progress and approved the outcome" of the reviews. Heidelberg Materials publishes an annual "Climate Advocacy and Association Review" (e.g., 2021, 2022, 2023), explaining that "we are reviewing our engagement in national trade associations annually" against six Paris-alignment criteria and disclosing the results (15 fully aligned, six partially misaligned, one misaligned in 2023). The methodology is detailed, involving desktop research, consultations with country representatives and "cross-checked through the Group Association Management," demonstrating a formal monitoring process. Concrete escalation steps are described: "If an associations position...differs from ours, we will increase our engagement and signal our dissent If the association repeatedly pursues policies and actions that are contrary to Heidelberg Materials positions we will publicly state our disagreement and finally review if exiting the association is appropriate." The company also discloses spending on both direct lobbying and association fees, reinforcing transparency. While the review appears to be conducted internally rather than by an external auditor, the combination of a publicly available assessment, board-level oversight, quarterly monitoring, and explicit actions to address misalignment indicates strong, comprehensive governance over both direct and indirect climate-related lobbying activities. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Heidelberg Materials describes a well-defined, publicly reported system for keeping both its direct and trade-association lobbying on climate issues aligned with its own net-zero strategy. The company states that its "Group Climate Policy is binding and applicable company-wide aimed at guiding all our advocacy activities," and it supplements the policy with three public affairs offices to enable "direct exchange with political decision makers." Oversight is clearly assigned: "The alignment of trade associations with goals of the Paris Agreement is quarterly reviewed with the Chief Sustainability Officer (CSO) and the board member responsible for associations," and these senior leaders "supervised the progress and approved the outcome" of the reviews. Heidelberg Materials publishes an annual "Climate Advocacy and Association Review" (e.g., 2021, 2022, 2023), explaining that "we are reviewing our engagement in national trade associations annually" against six Paris-alignment criteria and disclosing the results (15 fully aligned, six partially misaligned, one misaligned in 2023). The methodology is detailed, involving desktop research, consultations with country representatives and "cross-checked through the Group Association Management," demonstrating a formal monitoring process. Concrete escalation steps are described: "If an associations position...differs from ours, we will increase our engagement and signal our dissent If the association repeatedly pursues policies and actions that are contrary to Heidelberg Materials positions we will publicly state our disagreement and finally review if exiting the association is appropriate." The company also discloses spending on both direct lobbying and association fees, reinforcing transparency. While the review appears to be conducted internally rather than by an external auditor, the combination of a publicly available assessment, board-level oversight, quarterly monitoring, and explicit actions to address misalignment indicates strong, comprehensive governance over both direct and indirect climate-related lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Heidelberg Materials discloses climate-policy lobbying with a very high degree of detail. It names a wide range of concrete policy files it works on, including the EU Emissions Trading Scheme review, the Carbon Border Adjustment Mechanism, the Renewable Energy Directive (REDIII), the Net-Zero Industry Act, revision of the Construction Products Regulation, raw-material and waste-framework directives, green public-procurement rules such as U.S. “buy clean” programmes, the U.S. Inflation Reduction Act, funding instruments such as the EU Innovation Fund and CCUS support schemes, among others, and links each to its decarbonisation strategy. The company also explains exactly how and where it lobbies: it maintains representative offices in Berlin, Brussels and Washington to enable “a direct exchange between political decision makers and contact partners within the company,” holds “personal meetings” with “representatives of the European Commission and Members of the European Parliament,” participates in public consultations and parliamentary hearings, speaks at high-level fora such as COP27, and pursues indirect advocacy through trade bodies like CEMBUREAU and the GCCA. Targets are identified down to individual officials (e.g. meetings with Executive Vice-President Maroš Šefčovič and MEP Philippe Lambert) and to national ministries in Germany, Sweden, the U.S. and the UK. Finally, Heidelberg Materials is explicit about the outcomes it seeks: it pushes for “higher carbon pricing” and inclusion of cement in CBAM to prevent carbon leakage, calls for “rewarding the capture and storage of biogenic emissions” through tradable certificates, asks for “contracts for difference” and other funding mechanisms to scale renewable energy and hydrogen, advocates a “ban on landfilling” to boost alternative fuels, and supports revising product norms and building codes so that low-carbon cement can enter the market. By pairing specific policy positions with clearly described engagement channels and governmental targets, the company provides transparent and comprehensive insight into its climate-related lobbying activities.	A