ICADE

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Icade provides an unusually detailed picture of its climate-policy advocacy. It names several concrete measures it has engaged on, including the definition of the French “Label bas carbone”, the E+C- experimentation that underpins France’s 2022 thermal regulations, and the French Decree incorporated in Article 175 of Law Elan that requires a 60 % reduction in energy use and renovation of office buildings by 2050. The company also explains how it acts: it has held “discussions with the Centre Scientifique et Technique du Bâtiment (CSTB)” to develop new offset methodologies, worked through the industry body FSIF to submit suggestions on the office-building decree, collaborated with the French Ministry for Ecological Transition, and participates in the Corporate Forum on Sustainable Finance to “actively participate in the processes setting the future standards and regulatory frameworks for sustainable finance instruments.” Finally, it spells out the precise outcomes it is pursuing—securing approval of the “Renovation Method” and testing the “City with trees” method under the Label bas carbone, supporting the energy-reduction decree while seeking amendments, and targeting achievement of the E+C- label for all offices over 5,000 m² and half of new homes by 2022 at a minimum E2C1 rating. By disclosing the policies addressed, the channels and counterparts used, and the specific regulatory changes or performance thresholds it wants to see, Icade demonstrates a comprehensive level of transparency around its climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate ICADE discloses several elements that indicate a structured approach to governing its climate-related lobbying. It states that "the Innovation and CSR Committee which reports to the Board of Directors, ensures the coherence of our climate strategy and ensures that our direct and indirect activities influencing policies are consistent with our overall climate change and business strategy," naming a board-level body with explicit oversight of both direct and indirect engagement. The company also highlights that "our risk mapping managed by the Audit, Risk Management and Internal Control Department comprises a risk regarding influence practices with control measures associated. It thus ensures that all our activities that influence policy are supervised and are consistent with our overall CSR and business strategy," demonstrating that lobbying risks are monitored through an internal control framework. In addition, ICADE makes "a public commitment to conduct your engagement activities in line with the goals of the Paris Agreement," which signals an alignment objective. It has detailed some of the climate lobbying positions of four trade associations- ADIVbois, BBCA, EPRA (European Public Real Estate Association), and the French Federation of Real Estate Companies (FEI - Fdration des Entreprises de l'Immobilier)and that these positions are aligned with its own. However, the disclosure does not provide concrete details of the monitoring mechanismsuch as frequency, criteria, or outcomes of reviewsnor does it describe specific actions taken to engage, correct, or exit trade associations whose positions may conflict with its climate goals. Consequently, while there is a clear policy orientation and identified oversight, the company does not disclose a fully articulated process or evidence of active alignment actions, which limits the demonstration of comprehensive governance. 2