Titan Cement International SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Titan Cement International provides extensive and concrete information on all aspects of its climate-policy advocacy. It names several identifiable measures it has worked on – the EU ETS Directive and its revision, the Carbon Border Adjustment Mechanism, the wider “Fit-for-55” package, and the adoption of the EN 197-5 cement standard – showing exactly which pieces of legislation and standards it seeks to influence. The company also explains how it engages: it lobbies directly and through industry bodies such as CEMBUREAU and national cement associations, holds meetings with Greece’s Permanent Representation in Brussels and with DG-Climate officers, and approaches Members of the European Parliament and national competent authorities; in Kosovo its subsidiary Sharrcem “successfully lobbied with authorities to adopt the new EN 197-5 standard,” further illustrating the mechanisms and the policymaking targets. Finally, Titan is explicit about the outcomes it pursues, advocating that the ETS revision and CBAM include an export solution or, failing that, the retention of free allowances to preserve competitiveness and prevent carbon leakage, and aiming through EN 197-5 to “further optimize clinker factor” and lower CO₂ emissions. This level of specificity across policies, lobbying channels, and desired results demonstrates a high degree of transparency in the company’s climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Titan Cement International SA has established certain mechanisms to align its climate-related engagement activities, reporting that “Group positions are discussed, aligned, and approved at the Group level through our Sustainability Working Group and ExCom Sustainability Committee” and by making a public pledge through the “Business Ambition for 1.5°C Commitment” in support of the Paris Agreement. The company demonstrates indirect lobbying oversight via participation in sector bodies, noting that it “contributed to the development of the GCCA 2050 Roadmap to Net Zero Concrete ‘Concrete Future’” as a member of the Global Cement and Concrete Association and that its Executive Committee Chairman chairs the European Round Table for Industry’s “Energy Transition & Climate Change Working Group.” In addition, it states that the “Group Executive Committee and the Chief Sustainability and Innovation Officer” are responsible for policy and performance reviews, with “the Board of Directors conduct[ing] oversight.” However, we found no evidence of a formal process for ensuring alignment of direct government advocacy with its climate strategy or of a monitoring procedure for tracking such engagement beyond its trade-association coordination.	2