Novartis AG

Novartis describes its process for ensuring that "policy positions, targets and disclosures are aligned across Novartis through Executive Committee-level membership of the Environmental Sustainability Strategy Implementation Steering Committee, as well as via the Trust and Reputation Committee," and commits that "quarterly meetings are scheduled to align with the Government Affairs and Public Affairs offices for the US and European Union." It further clarifies that "the Novartis climate strategy and our commitment to become net zero by 2040 is used by our Communications and Engagement teams when they engage on climate related issues," and that "if any misalignment was identified ... the Sustainability & ESG office would seek to restore consistency between our position and any external advocacy." The company also affirms a public commitment "to conduct your engagement activities in line with the goals of the Paris Agreement." Oversight of these processes is provided by formal bodies, including the Sustainability & ESG office and the Trust and Reputation Committee, chaired by the CEO. However, the company does not disclose a structured process for evaluating or modifying its trade association memberships or other indirect lobbying channels against its climate goals, indicating that indirect lobbying alignment mechanisms are not fully articulated.