APERAM SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	APERAM SA provides a public commitment to conduct its external engagement in line with Paris Agreement goals, answering “Yes” when asked if it has a position statement to align engagement activities with the Paris Agreement. It also indicates it will “Communicate and engage with … policy-makers through our professional associations for the implementation of relevant Climate-Change policies and initiatives,” suggesting an intent to direct its indirect lobbying toward climate objectives. However, while the company refers to conducting “internal audits and reviews,” this applies to energy management, not a defined process for overseeing lobbying. We found no evidence of a specific individual or formal body responsible for reviewing lobbying alignment, nor any detailed monitoring or sign-off procedures to ensure that direct or indirect lobbying activities remain consistent with its climate commitments, indicating limited governance disclosure on this front. View Sources	D

Overall Assessment

Analysis

Score

Limited

APERAM SA provides a public commitment to conduct its external engagement in line with Paris Agreement goals, answering “Yes” when asked if it has a position statement to align engagement activities with the Paris Agreement. It also indicates it will “Communicate and engage with … policy-makers through our professional associations for the implementation of relevant Climate-Change policies and initiatives,” suggesting an intent to direct its indirect lobbying toward climate objectives. However, while the company refers to conducting “internal audits and reviews,” this applies to energy management, not a defined process for overseeing lobbying. We found no evidence of a specific individual or formal body responsible for reviewing lobbying alignment, nor any detailed monitoring or sign-off procedures to ensure that direct or indirect lobbying activities remain consistent with its climate commitments, indicating limited governance disclosure on this front.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	APERAM SA provides only limited transparency about its climate-related lobbying. The company indicates that it participates in Eurofer and other industry bodies and allocates funds to “public affairs and trade-defence activities,” which reveals an indirect lobbying mechanism, but it does not describe the nature of those engagements or name the governmental bodies it seeks to influence. Its disclosures reference broad policy areas such as the European Green Deal, EU Taxonomy alignment, carbon markets and trade-defence measures, yet no specific bills, regulations or consultations are identified. Likewise, the company outlines general aspirations—support for climate-neutrality by 2050 and a “level playing field” in global trade—without detailing concrete legislative changes or measurable outcomes it is pursuing. As a result, readers gain only a high-level sense of the company’s lobbying involvement, with few specifics about the policies, tactics or goals underlying that activity.	D