Deutsche Boerse AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Deutsche Börse AG demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate-related issues. The company has established structures such as the Group Regulatory Strategy (GRS) area, which includes a dedicated ESG Strategy Unit that "responds directly to the Chief Executive Office (CEO) Division" and ensures that "position papers and other activities such as reports or presentations are developed together and hence are consistent and in line with the strategy of Deutsche Börse Group." This indicates a process for aligning external engagement with the company's climate strategy. Additionally, the Supervisory Board and its committees, including the Strategy and Sustainability Committee, Audit Committee, Risk Committee, and Nomination Committee, play roles in overseeing ESG and climate-related tasks, such as "updates on ESG strategy, activities, and priorities" and "discussion about the quarterly compliance and Risk Management reports including ESG and climate risks." The Executive Board also has "ultimate joint responsibility as well as ownership of ESG topics, including Deutsche Börse Group’s climate strategy," and is informed bi-monthly through dedicated reports. However, while these structures and processes suggest oversight and alignment mechanisms, there is no explicit evidence of a detailed lobbying audit or review that evaluates alignment of both direct and indirect lobbying activities with climate goals. Furthermore, while the company mentions monitoring and development of its climate strategy and engagement with policymakers, it does not disclose specific actions taken to address misalignment in trade associations or other indirect lobbying channels. The governance framework is moderately strong but lacks comprehensive monitoring details and explicit coverage of both direct and indirect lobbying alignment. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Deutsche Börse AG demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate-related issues. The company has established structures such as the Group Regulatory Strategy (GRS) area, which includes a dedicated ESG Strategy Unit that "responds directly to the Chief Executive Office (CEO) Division" and ensures that "position papers and other activities such as reports or presentations are developed together and hence are consistent and in line with the strategy of Deutsche Börse Group." This indicates a process for aligning external engagement with the company's climate strategy. Additionally, the Supervisory Board and its committees, including the Strategy and Sustainability Committee, Audit Committee, Risk Committee, and Nomination Committee, play roles in overseeing ESG and climate-related tasks, such as "updates on ESG strategy, activities, and priorities" and "discussion about the quarterly compliance and Risk Management reports including ESG and climate risks." The Executive Board also has "ultimate joint responsibility as well as ownership of ESG topics, including Deutsche Börse Group’s climate strategy," and is informed bi-monthly through dedicated reports. However, while these structures and processes suggest oversight and alignment mechanisms, there is no explicit evidence of a detailed lobbying audit or review that evaluates alignment of both direct and indirect lobbying activities with climate goals. Furthermore, while the company mentions monitoring and development of its climate strategy and engagement with policymakers, it does not disclose specific actions taken to address misalignment in trade associations or other indirect lobbying channels. The governance framework is moderately strong but lacks comprehensive monitoring details and explicit coverage of both direct and indirect lobbying alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Deutsche Börse AG has demonstrated comprehensive transparency in its climate lobbying activities, clearly naming the specific policies it engages on, detailing its lobbying methods, and articulating the outcomes it seeks. It explicitly identifies its engagement with key EU climate frameworks, including the "European Green Deal" and related legislative measures such as the "Climate Law," "EU Emissions Trading Scheme," and "Renewable Energy Directive." The company is "registered in the EU’s Transparency Register" and discloses a range of direct and indirect mechanisms—participation in "public consultations," submission of "position papers," organization of "bilateral meetings," and contributions through "sectoral associations’ similar activities"—targeting EU administrations and policymakers in its role as the EU and German auctioning platform for emissions trading. Finally, Deutsche Börse AG clearly outlines its desired policy outcomes, advocating for "subsidy schemes most aligned with the market and a cost-efficient transition," supporting "an ever-increasing share of renewable energy and a market-based energy transition," and arguing in "favor of applying an emissions trading scheme to economic sectors."	4