Henkel AG & Co KGaA

Henkel provides some insight into how it governs the alignment of its climate-related engagement activities, noting that "our sustainability council plays the central role to perform coordination, initiative and control functions in relation to sustainability issues" and that this committee is "made up of managers from all business units and functions." The disclosure outlines a process whereby "corporate functions support the implementation of our sustainability strategy... such as leveraging external stakeholder engagement," while regional managers "develop and steer local engagement projects based on Henkel's sustainability strategy," indicating an internal mechanism for monitoring direct engagement. For indirect advocacy through industry bodies, Henkel states that "new engagement activities could be triggered in cases of potential unalignment on our sustainability targets with the associations we are a member of," showing that it assesses and, where necessary, responds to misalignment with trade associations. The company also declares a public commitment to conduct its engagement "in line with the goals of the Paris Agreement." However, Henkel does not disclose how frequently the sustainability council reviews lobbying positions, provide details of any dedicated climate-lobbying audit, nor explicitly confirm that direct lobbying of policymakers is systematically checked for alignment, so the breadth and formality of the governance process remain only moderately clear.