Ayvens SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Ayvens discloses a clearly structured process to keep its policy advocacy aligned with its climate strategy, stating that "we aim at engaging with trade associations (and NGOs) that are advocating to create a favorable ecosystem for Electric Vehicles which are the main pillar of our climate strategy" and that, at European level, the Head of Corporate Social Responsibility personally represents the company in ChargeUp Europe and other climate-focused platforms. The company sets out an internal review mechanism whereby "decisions [on positions] are taken by the business lines with the approval of the Chief Sustainability Officer (CSO)", while "2 FTEs are assigned to sustainable finance regulations and work with the CSO and impacted business lines, to ensure that positions are discussed and approved before any advocacy occurs." Oversight is further institutionalised through a Public Affairs Steering Committee that "compris[es] (i) all business and support functions with regulatory responsibilities (Risk, Compliance, Finance, CSO) and (ii) all public affairs officers" and meets "every 2 weeks" so that "CSR topics are thoroughly discussed." These disclosures demonstrate a defined governance process covering both direct engagement (e.g., local General Managers "carry the voice of ALD") and indirect lobbying through trade associations, with explicit sign-off by the CSO and a standing committee that reviews advocacy on a regular cadence—indicating strong governance. However, the company does not disclose a formal public audit or review of its lobbying alignment, nor evidence of corrective action with trade associations whose positions may diverge from its climate commitments, leaving limited transparency on how the effectiveness of this governance is evaluated. View Sources	3

Overall Assessment

Analysis

Score

Strong

Ayvens discloses a clearly structured process to keep its policy advocacy aligned with its climate strategy, stating that "we aim at engaging with trade associations (and NGOs) that are advocating to create a favorable ecosystem for Electric Vehicles which are the main pillar of our climate strategy" and that, at European level, the Head of Corporate Social Responsibility personally represents the company in ChargeUp Europe and other climate-focused platforms. The company sets out an internal review mechanism whereby "decisions [on positions] are taken by the business lines with the approval of the Chief Sustainability Officer (CSO)", while "2 FTEs are assigned to sustainable finance regulations and work with the CSO and impacted business lines, to ensure that positions are discussed and approved before any advocacy occurs." Oversight is further institutionalised through a Public Affairs Steering Committee that "compris[es] (i) all business and support functions with regulatory responsibilities (Risk, Compliance, Finance, CSO) and (ii) all public affairs officers" and meets "every 2 weeks" so that "CSR topics are thoroughly discussed." These disclosures demonstrate a defined governance process covering both direct engagement (e.g., local General Managers "carry the voice of ALD") and indirect lobbying through trade associations, with explicit sign-off by the CSO and a standing committee that reviews advocacy on a regular cadence—indicating strong governance. However, the company does not disclose a formal public audit or review of its lobbying alignment, nor evidence of corrective action with trade associations whose positions may diverge from its climate commitments, leaving limited transparency on how the effectiveness of this governance is evaluated.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Ayvens SA provides detailed transparency around its climate lobbying activities by clearly identifying the specific policies it has engaged with, the channels it has used, and the outcomes it seeks. In terms of policies, the company names its support for the French requirement on non-financial information reporting (Art. 173), its backing for “mandatory disclosure of the non-financial information in France and at international level through TCFD recommendations,” and its signing of the Green Investment Principles in November 2019. Regarding mechanisms, it specifies that it “follow[s] and influence[s] the workstreams of HLEG2 through the European Banking Federation (EBF),” has “replied to the TCFD public consultation,” and has “supported French legislators and administration on the implementation of the disclosure of non-financial information by French companies (Art. 173).” Finally, it is explicit about its desired outcomes: it advocates for mandatory non-financial disclosure aligned with TCFD and urges the European Commission to “recognise the importance and include the financial industry as much as institutional investors.” This combination of named policies, identifiable engagement methods, and concrete policy end goals demonstrates strong transparency in Ayvens SA’s climate lobbying disclosures.	3