Orange SA

Orange SA has implemented a structured governance process to ensure its policy engagement is aligned with its climate objectives, with the "Executive Committee of Orange Group" explicitly tasked with supervising "the coherence and the consistency between the Climate Change Strategy of Orange and the different engagements influencing policy." The Committee "reviews and validates the detailed strategies elaborated by the different business divisions and geographies" and ensures continued performance by tracking climate change action plans "through internal indicators." Oversight is further embedded in an Environmental division that "defines, coordinates, and regularly monitors its engagement activities to ensure the consistency with the overall climate change strategy," including through preparatory steering committees on scope 3 trajectories and other environmental subjects. This governance extends to indirect lobbying via industry bodies, as "the main engagements of the Orange Group, namely its activities within the GSMA, the ITU, the EC and the JAC" are "supervised by the Environmental division and closely followed by executive committee." Moreover, Orange has made a public commitment to conduct its engagement activities "in line with the goals of the Paris Agreement." While this framework clearly identifies formal bodies responsible for alignment and sets out regular review processes, the company does not disclose a dedicated review of direct lobbying activities or an independent, detailed audit of its climate‐lobbying alignment, suggesting room for deeper external verification.