DSM-Firmenich AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	DSM-Firmenich discloses a clear internal process for assessing whether its policy engagement aligns with its climate strategy: “The Global Environmental Team first gains a deep understanding of any potential direct or indirect activities… determines whether the activities are properly aligned with our overall climate change strategy. If activities are aligned, they will be proposed to the Senior VP, Global QHS&E for approval. If activities are not aligned, participation may be declined or modified to maintain alignment.” This shows that engagement proposals, including lobbying through industry bodies, are reviewed and can be rejected or altered to maintain alignment, indicating a concrete mechanism for monitoring and managing lobbying alignment. Oversight responsibility is explicitly assigned, as the Global Environmental Team “reports directly to the Senior Vice President, Global Quality, Health, Safety, and Environment (QHS&E),” and at a higher level “our Sustainability Committee and Executive Committee oversee our Climate and Nature agenda,” demonstrating named individuals and committees involved in sign-off and supervision. The company also states it has “a public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement,” confirming a policy intention to align external advocacy with climate goals. However, the disclosure stops short of detailing how direct corporate lobbying and memberships in “various industry associations and advocacy organizations” are systematically assessed for climate-policy consistency, and it provides no examples of taking corrective action with specific associations or any published audit of lobbying alignment. We found no evidence of a public report comparing the company’s positions to those of its trade associations or of third-party verification of alignment. This indicates a moderate level of governance: a defined internal review process with senior oversight and a climate-aligned commitment, but without the fuller transparency, documented trade-association management, or public lobbying audit that would demonstrate stronger governance. View Sources	C

Overall Assessment

Analysis

Score

Moderate

DSM-Firmenich discloses a clear internal process for assessing whether its policy engagement aligns with its climate strategy: “The Global Environmental Team first gains a deep understanding of any potential direct or indirect activities… determines whether the activities are properly aligned with our overall climate change strategy. If activities are aligned, they will be proposed to the Senior VP, Global QHS&E for approval. If activities are not aligned, participation may be declined or modified to maintain alignment.” This shows that engagement proposals, including lobbying through industry bodies, are reviewed and can be rejected or altered to maintain alignment, indicating a concrete mechanism for monitoring and managing lobbying alignment. Oversight responsibility is explicitly assigned, as the Global Environmental Team “reports directly to the Senior Vice President, Global Quality, Health, Safety, and Environment (QHS&E),” and at a higher level “our Sustainability Committee and Executive Committee oversee our Climate and Nature agenda,” demonstrating named individuals and committees involved in sign-off and supervision. The company also states it has “a public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement,” confirming a policy intention to align external advocacy with climate goals. However, the disclosure stops short of detailing how direct corporate lobbying and memberships in “various industry associations and advocacy organizations” are systematically assessed for climate-policy consistency, and it provides no examples of taking corrective action with specific associations or any published audit of lobbying alignment. We found no evidence of a public report comparing the company’s positions to those of its trade associations or of third-party verification of alignment. This indicates a moderate level of governance: a defined internal review process with senior oversight and a climate-aligned commitment, but without the fuller transparency, documented trade-association management, or public lobbying audit that would demonstrate stronger governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	DSM-Firmenich provides only selective insight into its climate-policy lobbying. It names a single concrete initiative – the “GHG Protocol Carbon Removals and Land Sector Initiative,” where it participates in the Technical Working Group to help shape new accounting standards for land-sector emissions and removals – but does not identify any other specific laws or regulations it seeks to influence. The company describes a handful of engagement channels, including meetings with China’s Ministry of Commerce, attendance by its China President at the Green and Low Carbon Development Forum hosted by the Ministry of Industry and Information Technology and the China Enterprise Confederation, signing a Fossil-to-Clean open letter to national governments, and serving on WRI/WBCSD working groups. These examples show at least two distinct mechanisms (formal working-group participation and direct ministerial meetings) and name the relevant targets, yet most other references remain generic (“dialogues,” “industry coalitions”). With respect to objectives, the company is explicit only in supporting the development of new GHG Protocol guidance “to account for land sector activities and CO2 removals in corporate GHG inventories,” while broader statements about net-zero ambitions and renewable-energy use are framed as internal goals rather than policy asks. Overall, the disclosures reveal limited transparency, offering scattered details rather than a systematic account of which climate policies the company engages on, how it lobbies, and the concrete outcomes it pursues.	D