Koninklijke KPN NV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Koninklijke KPN NV demonstrates a strong governance framework aligning its lobbying activities with its climate strategy. The company has established “multiple lines of communication that interact on a frequent basis,” including a “quarterly Energy and Environment board” chaired by the Strategic Lead Energy & Environment, “quarterly sustainability board” meetings with regional management, public affairs, and sales, “quarterly updates to the Board of Management based on our climate strategy including KPI updates,” as well as a “quarterly meeting with our external auditor (outside-in perspective/validation of frameworks applied/trends in regulation/reporting).” The Energy & Environment Department “coordinates all climate and energy efficiency related activities and partnerships and also the multiple engagement activities around climate change,” maintaining “direct communication between the Energy & Environment Department and the Public Affairs department about lobby activities with various bodies (VNO-NCW, NL Digital , VEMW) and communications with government (ao ministry of Economic Affairs and Climate Policy) to ensure alignment with the position relating to Climate Agreements.” Oversight is clearly assigned: the Strategic Lead Energy & Environment reports to the Chief Technology Officer, while the VP Communications & CSR “reports directly into the CEO,” ensuring integration of climate policy in external communications. In addition, KPN has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” and applies the “CDP Supplier Engagement programme” to assess its key vendors’ Paris-alignment. While these disclosures indicate strong governance of both direct and indirect lobbying, we found no evidence of a publicly available climate-lobbying audit or any commissioned third-party review explicitly evaluating lobbying alignment with its climate goals. View Sources	B

Overall Assessment

Analysis

Score

Strong

Koninklijke KPN NV demonstrates a strong governance framework aligning its lobbying activities with its climate strategy. The company has established “multiple lines of communication that interact on a frequent basis,” including a “quarterly Energy and Environment board” chaired by the Strategic Lead Energy & Environment, “quarterly sustainability board” meetings with regional management, public affairs, and sales, “quarterly updates to the Board of Management based on our climate strategy including KPI updates,” as well as a “quarterly meeting with our external auditor (outside-in perspective/validation of frameworks applied/trends in regulation/reporting).” The Energy & Environment Department “coordinates all climate and energy efficiency related activities and partnerships and also the multiple engagement activities around climate change,” maintaining “direct communication between the Energy & Environment Department and the Public Affairs department about lobby activities with various bodies (VNO-NCW, NL Digital , VEMW) and communications with government (ao ministry of Economic Affairs and Climate Policy) to ensure alignment with the position relating to Climate Agreements.” Oversight is clearly assigned: the Strategic Lead Energy & Environment reports to the Chief Technology Officer, while the VP Communications & CSR “reports directly into the CEO,” ensuring integration of climate policy in external communications. In addition, KPN has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” and applies the “CDP Supplier Engagement programme” to assess its key vendors’ Paris-alignment. While these disclosures indicate strong governance of both direct and indirect lobbying, we found no evidence of a publicly available climate-lobbying audit or any commissioned third-party review explicitly evaluating lobbying alignment with its climate goals.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Koninklijke KPN NV discloses engagement on the Energy Saving Obligation under the environmental management Activities Decree. It describes engaging “directly and indirectly via NL Digital (representing the ICT/digital branch)” with “policy makers” in the Netherlands. The company states it seeks to demonstrate compliance by implementing all energy-saving measures with a payback time of less than five years, maintain its multi-year agreement and ISO 14001 certification to avoid audits or fines, and supports the policy “with no exceptions.” These disclosures offer clear insight into the lobbying mechanism and outcomes sought but are limited to a single named policy and refer to targets in broad terms.	C