SES SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	SES indicates that it applies a defined oversight structure to keep its climate-related engagement activities aligned with its wider climate strategy, noting that "SES climate activities are managed across the business by the ESG team reporting into the Chief Legal Officer" and that this team "works through internal stakeholders to assure processes, policies and targets are updated and aligned with SES climate goals." This shows a named governance channel—the ESG team under the Chief Legal Officer—responsible for monitoring and updating activities that include external engagement. In addition, the company confirms that it maintains "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," signalling an explicit intention to align its advocacy with internationally recognised climate objectives. However, the disclosure does not describe any detailed procedures for assessing or correcting misalignment in either direct lobbying or trade-association positions, nor does it mention publication of a lobbying review or other transparency mechanisms. As a result, while SES provides evidence of oversight and an alignment commitment, the publicly available information on how it actively manages both direct and indirect lobbying remains limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

SES indicates that it applies a defined oversight structure to keep its climate-related engagement activities aligned with its wider climate strategy, noting that "SES climate activities are managed across the business by the ESG team reporting into the Chief Legal Officer" and that this team "works through internal stakeholders to assure processes, policies and targets are updated and aligned with SES climate goals." This shows a named governance channel—the ESG team under the Chief Legal Officer—responsible for monitoring and updating activities that include external engagement. In addition, the company confirms that it maintains "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," signalling an explicit intention to align its advocacy with internationally recognised climate objectives. However, the disclosure does not describe any detailed procedures for assessing or correcting misalignment in either direct lobbying or trade-association positions, nor does it mention publication of a lobbying review or other transparency mechanisms. As a result, while SES provides evidence of oversight and an alignment commitment, the publicly available information on how it actively manages both direct and indirect lobbying remains limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	SES SA provides a fair degree of transparency on its climate-related lobbying. It names two specific EU initiatives it has engaged on – the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) – and locates this work within the broader category of “climate-related reporting” in Luxembourg. The company also explains how and with whom it engages, stating that it conducts “group and 1 on 1 meetings” with clearly identified targets such as the “EU Commission,” the “ESA,” and the “Luxembourg Chamber of Commerce.” Finally, it is open about the outcomes it is pursuing: it “generally supports more transparency and reporting,” indicates “Support with minor exceptions,” and voices “concerns about how this will be enforced and the degree of support from the government on implementation,” confirming that its stance is intended to remain “aligned with the Paris Agreement.” Together, these details show moderate but not exhaustive disclosure across the policy, mechanism, and outcome dimensions of its climate lobbying.	C