GCC SAB de CV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	GCC SAB de CV discloses some mechanisms aimed at keeping its policy engagement consistent with its climate strategy, noting that it has “a public commitment … to conduct [our] engagement activities in line with the goals of the Paris Agreement” and that it “participates and engages with industry leading initiatives on climate change through leadership and collaboration to develop industry roadmaps for carbon neutral cement and concrete.” The company also provides examples of acting to align indirect lobbying, explaining that its President “is the Chairman of the Board for [the] Portland Cement Association and played an integral role in the visionary leadership to develop a carbon-neutral roadmap for the industry,” while its VP of Sustainability “was one of five Task Group Leaders for PCA’s Climate and Sustainability Council, driving PCA member companies commitments to achieving carbon neutrality.” These statements indicate that senior executives are working within key trade associations to steer them toward net-zero positions, which suggests an effort to align indirect lobbying with the firm’s climate objectives. However, the disclosure does not set out a formal internal governance structure: apart from mentioning that the “CEO and Board Member is on the Board [of] the Global Cement and Concrete Association,” it does not specify a board committee or individual charged with reviewing lobbying alignment, nor does it describe any recurring review, audit, or sign-off process for either direct or indirect lobbying. There are likewise no details on how the company monitors its state-level lobbying or evaluates associations for potential misalignment. The evidence therefore shows a policy commitment and some concrete actions toward alignment, but lacks a clearly defined oversight mechanism, documented monitoring procedures, or public reporting of outcomes. View Sources	2

Overall Assessment

Analysis

Score

Moderate

GCC SAB de CV discloses some mechanisms aimed at keeping its policy engagement consistent with its climate strategy, noting that it has “a public commitment … to conduct [our] engagement activities in line with the goals of the Paris Agreement” and that it “participates and engages with industry leading initiatives on climate change through leadership and collaboration to develop industry roadmaps for carbon neutral cement and concrete.” The company also provides examples of acting to align indirect lobbying, explaining that its President “is the Chairman of the Board for [the] Portland Cement Association and played an integral role in the visionary leadership to develop a carbon-neutral roadmap for the industry,” while its VP of Sustainability “was one of five Task Group Leaders for PCA’s Climate and Sustainability Council, driving PCA member companies commitments to achieving carbon neutrality.” These statements indicate that senior executives are working within key trade associations to steer them toward net-zero positions, which suggests an effort to align indirect lobbying with the firm’s climate objectives. However, the disclosure does not set out a formal internal governance structure: apart from mentioning that the “CEO and Board Member is on the Board [of] the Global Cement and Concrete Association,” it does not specify a board committee or individual charged with reviewing lobbying alignment, nor does it describe any recurring review, audit, or sign-off process for either direct or indirect lobbying. There are likewise no details on how the company monitors its state-level lobbying or evaluates associations for potential misalignment. The evidence therefore shows a policy commitment and some concrete actions toward alignment, but lacks a clearly defined oversight mechanism, documented monitoring procedures, or public reporting of outcomes.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	GCC SAB de CV provides a robust picture of its climate-policy lobbying. It explicitly identifies two concrete policies it has tried to influence – the “Greenhouse Gas Emissions and Energy Management for Manufacturing in Colorado (GEMM)” rule-making and participation in the pilot phase of the “Mexico Emissions Trading System (ETS)” – giving policy names, geographic scope and subject matter. The company also describes multiple, specific channels through which it lobbies and whom it targets: it “collaborated with NGOs, state agencies, legislators, and the air quality commissions to develop the rule-making,” took part in “CANACEM GCC” and held “discussions with SEMARNART,” and notes that its “Chief Sustainability Officer was heavily involved in the development of GEMM rule-making for 6-8 months.” By detailing collaboration, formal participation and direct discussions – and naming the public bodies involved – the company shows clear transparency about its lobbying mechanisms and counterparts. On desired outcomes, GCC states its “support with no exceptions” for the GEMM regulation and its ambition “to finish establishing the rules to operate the Mexico ETS,” confirming both efforts are “aligned with the Paris Agreement.” While these disclosures outline the main objectives rather than numerical targets, they nonetheless articulate specific policy results the company seeks. Altogether, the disclosures demonstrate a strong level of transparency across policy focus, methods and intended outcomes of the company’s climate-related lobbying.	3