FLSmidth & Co A/S – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	FLSmidth has implemented its climate engagement governance by centering activities around its MissionZero programme, which "is the starting point of our engagement activities with industry associations and initiatives," and conducts "a desk-based exercise" whereby "we therefore review the various mission statements when they exist, or major communications, from industry associations we are engaging at Group Level to spot any inconsistencies with either our overall MissionZero ambition level and Paris Agreements." The company also affirms a "public commitment or position statement to conduct engagement activities in line with the goals of the Paris Agreement." Oversight of these sustainability-linked engagement processes is provided by a strong governance structure in which the Board of Directors "addresses sustainability updates every quarter and conducts an annual sustainability review" and Group Executive Management "acts as the company’s Sustainability Board and holds overall accountability for the direction, progress and focus of our sustainability work." However, the company does not disclose equivalent measures for governing its direct lobbying activities, does not identify specific individuals responsible for reviewing or correcting misaligned policy positions, and provides no criteria for influencing or exiting industry associations, indicating that its governance of climate lobbying remains partial and could benefit from more dedicated processes and accountability mechanisms. View Sources	C

Overall Assessment

Analysis

Score

Moderate

FLSmidth has implemented its climate engagement governance by centering activities around its MissionZero programme, which "is the starting point of our engagement activities with industry associations and initiatives," and conducts "a desk-based exercise" whereby "we therefore review the various mission statements when they exist, or major communications, from industry associations we are engaging at Group Level to spot any inconsistencies with either our overall MissionZero ambition level and Paris Agreements." The company also affirms a "public commitment or position statement to conduct engagement activities in line with the goals of the Paris Agreement." Oversight of these sustainability-linked engagement processes is provided by a strong governance structure in which the Board of Directors "addresses sustainability updates every quarter and conducts an annual sustainability review" and Group Executive Management "acts as the company’s Sustainability Board and holds overall accountability for the direction, progress and focus of our sustainability work." However, the company does not disclose equivalent measures for governing its direct lobbying activities, does not identify specific individuals responsible for reviewing or correcting misaligned policy positions, and provides no criteria for influencing or exiting industry associations, indicating that its governance of climate lobbying remains partial and could benefit from more dedicated processes and accountability mechanisms.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	FLSmidth & Co A/S provides only limited visibility into its climate-related lobbying. It refers in broad terms to engaging on the European Green Deal, the EU taxonomy and “energy efficiency requirements,” but it does not identify any specific pieces of legislation or regulatory proposals it has addressed. Its description of activity is likewise high-level: the company speaks of “awareness raising to the latest emission reducing or water efficient technologies” and cites its membership of the UN Leadership Group for Industry Transition (UN LEADIT), yet it does not disclose concrete mechanisms such as meetings, submissions or letters, nor does it name the policymakers or governmental bodies it approaches. On outcomes, the company states that it “supports the objectives of the European Green Deal and EU taxonomy” and seeks to “raise the ambitions of our customers and support their climate strategies,” but it offers no clear policy positions, targets or amendments it is advocating. Overall, the disclosures convey a general commitment to constructive engagement without detailing the specific policies, channels or results the company is pursuing.	D