Imerys SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Imerys has introduced a baseline governance framework for its lobbying activities with explicit climate alignment requirements but stops short of detailing how it manages or monitors these efforts. The company’s Code of Business Conduct requires that “any lobbying activities that we undertake must fully reflect the ethical values of this Code,” and affirms that “the alignment with the goals of the Paris Agreement, our climate change strategy and our other commitments about sustainability is evaluated systematically,” indicating a formal policy to tie lobbying to climate objectives. Accountability is assigned clearly, as the Group “appointed a Vice President for Public Affairs responsible for the oversight of these activities,” who “reports to the Chief Human Resources Officer… and regularly informs the Chief Executive Officer of the activities undertaken.” However, Imerys does not disclose any specific process for reviewing or approving lobbying positions, nor does it explain how it manages its indirect engagement through professional associations to ensure consistency with its climate policy, and we found no evidence of board or committee-level review or a dedicated climate lobbying audit. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Imerys has introduced a baseline governance framework for its lobbying activities with explicit climate alignment requirements but stops short of detailing how it manages or monitors these efforts. The company’s Code of Business Conduct requires that “any lobbying activities that we undertake must fully reflect the ethical values of this Code,” and affirms that “the alignment with the goals of the Paris Agreement, our climate change strategy and our other commitments about sustainability is evaluated systematically,” indicating a formal policy to tie lobbying to climate objectives. Accountability is assigned clearly, as the Group “appointed a Vice President for Public Affairs responsible for the oversight of these activities,” who “reports to the Chief Human Resources Officer… and regularly informs the Chief Executive Officer of the activities undertaken.” However, Imerys does not disclose any specific process for reviewing or approving lobbying positions, nor does it explain how it manages its indirect engagement through professional associations to ensure consistency with its climate policy, and we found no evidence of board or committee-level review or a dedicated climate lobbying audit.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Imerys SA does not disclose any direct lobbying activities related to climate policy. The company’s disclosures focus on operational partnerships and projects—such as its UK lithium mining initiative and the EMILI project in France—without naming or engaging specific climate laws, regulations, or policy targets. There is no information on letters, meetings, consultations, or other lobbying mechanisms, nor any identified governmental bodies or officials that Imerys has approached on climate matters. While Imerys expresses general support for climate change targets and emission reductions, it does not specify any legislative or regulatory outcomes it seeks to influence. This limited level of detail indicates minimal transparency regarding its climate-related lobbying.	D