Cemex Disclosure Scorecard

Detailed assessment of Cemex's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of Cemex's disclosures on climate policy engagement. This does not include an assessment of the company's real-world climate policy engagement, which can be found on InfluenceMap's online profile of Cemex, accessible via the buttons on the right hand side of the page.

The disclosure assessments are directly integrated into the CA100+ Net Zero Company Benchmark as part of InfluenceMap's Climate Policy Engagement Alignment’ assessment, under two distinct indicators:

  • Accuracy of Climate Policy Engagement Disclosures: An assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
  • Robustness of Corporate Climate Policy Engagement Review & Misalignment Management Processes: An assessment of the quality and robustness of a company's process to identify, report on, and address specific cases of misalignment between its climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.

In 2023, InfluenceMap’s methodology to assess corporate disclosures on climate policy engagement was formally updated in line with the Global Standard on Responsible Climate Lobbying and stakeholder input. The detailed methodology - as well as additional resources including best practice guidance and Cemex's company profile - is accessible via the buttons on the right hand side of the page.

Accuracy of Climate Policy Engagement Disclosure: Summary

A summary of Cemex's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.

IndicatorScore
Accuracy of Climate Policy Engagement DisclosurePartial, meets some criteria
Sub-IndicatorScore
Accuracy of Direct Climate Policy Engagement DisclosureYes, meets criteria
Accuracy of Indirect Climate Policy Engagement DisclosureNo, does not meet criteria

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Summary

A summary of Cemex's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.

The Review Score (0-100) assesses corporate performance against seven indicators, using the same traffic-light framework. A ‘Green’ scores 2 points, a ‘Yellow’ scores 1 point, and a ‘Red’ scores 0 points. This total is converted into a percentage from 0 to 100, calculated using the total number of points available (14). As such, only certain scores within the 0 to 100 range are possible under this methodology. A Review Score of 100 would indicate that a company has met all of the assessment criteria related to the review process.

Date of ReviewScore
March 20242/14 (14%)
February 20254/14 (29%)

Accuracy of Climate Policy Engagement Disclosure: Scorecard

This is an assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.

InfluenceMap utilizes its proprietary database to assess how corporate disclosures on climate policy positions and engagement activities compare to InfluenceMap's independent assessment of the companies' and industry associations' real-world climate policy engagement. In short, it assesses the extent to which the company has disclosed on all climate policy engagement identified by InfluenceMap's database.

The tables below provide: (1) a breakdown of Cemex's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.

Has the company published an accurate account of its corporate climate policy positions and engagement activities (as compared to InfluenceMap’s database)?

Cemex

Cemex has published a broadly complete account of its positions and engagement activities on specific climate-related policies, but excludes 1 material evidence of direct climate policy engagement identified by InfluenceMap's database.

Cemex's 2024 Integrated Report discloses the company's engagement on the EU Carbon Border Adjustment Mechanism, Mexican Emissions Trading System, and UK CCUS policies. However, Cemex has excluded its comments on the EPA Label Program for Low Embodied Carbon Construction Materials in March 2024.

Best Practice

Enel has published a complete and accurate account of its positions and engagement activities on specific climate-related policies, and this is aligned with InfluenceMap's assessment of the company using its LobbyMap database. Enel included its climate advocacy activities, positions, and links to the company’s government consultation responses to specific climate-related policies from 2022-2024 in its 2023 Climate Policy Advocacy report, published April 2024. It also covered a range of regions in its disclosure, including Global, Europe, North & South America, Africa, and the Asia Pacific.

BP partially met the assessment criteria under this indicator, as it excluded material evidence of climate policy engagement. However, BP’s ‘Advocacy Activities’ webpage provides a clear and detailed disclosure of the company’s climate policy engagement, with filters for jurisdiction; date; and topic, including links to relevant consultation responses. It also contains sorting options for most recent, and most relevant.

Has the company published an accurate account of the climate policy positions and engagement activities of the industry associations of which it is a member (as compared to InfluenceMap’s database)?

Cemex

Cemex has disclosed a list of its industry association memberships, but it excludes its membership to Confederación Patronal de la República Mexicana (Coparmex), Corporate Leaders Group and Confederation of British Industry (CBI).

Cemex does not appear to have disclosed an account of its industry associations' positions and engagement activities with reference to specific climate policies. Cemex has therefore excluded key instances of engagement with specific climate-related policies by its industry associations. For example, CEMBUREAU engaged on the EU Emissions Trading System in January 2024.

See Appendix A below for details of the company's industry association memberships.

Best Practice

Unilever has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. In its March 2024 industry association review, the company attached LobbyMap profile links to each association’s assessment. Iberdrola published a largely complete and accurate of its industry associations' positions and engagement activities on specific climate-related policies.

Iberdrola and its North American subsidiary Avangrid both disclosed the climate policy engagement activities of their industry associations in their respective industry association climate lobbying reviews.

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Scorecard - 4/14 (29%)

This is an assessment of the quality and robustness of a company's processes to identify, report on, and address specific cases of misalignment between its climate policy engagement activities (direct and indirect) and delivering the 1.5°C goal of the Paris Agreement.

The Review Score is split into seven indicators, which fall within one of three categories:

  • Review Process: Does the company have clear and robust governance processes to regularly assess alignment against the 1.5°C goal of the Paris Agreement, and address potential cases of misalignment?

  • Review Assessment (Direct - Company): Has the company identified and addressed specific cases of misalignment between its direct - i.e. corporate - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?

  • Review Assessment (Indirect – Industry Associations): Has the company identified and addressed specific cases of misalignment between its indirect – i.e. via industry associations - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?

The table below provides an overview of Cemex's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.

Review ProcessReview Assessment (Direct)Review Assessment (Indirect)
Monitor & ReviewIdentify & AssessIdentify & Assess
Alignment Assessment MethodActAct
Framework for Misalignment

The tables below provide: (1) a breakdown of Cemex's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.

Review Process

Has the company established an annual monitoring and review process to ensure that all of its direct and/or indirect climate policy engagement activities across all geographies are consistent with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels?

Cemex

Cemex published its first review of its industry associations’ climate alignment in March 2024, and has now published its second review in February 2025 covering the calendar year 2024. The company has committed to carrying out its review process on a biannual basis to continually assess alignment.

Best Practice

Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2024, with detailed updates on misaligned industry associations each year. The company has committed to continue reviewing its memberships on an annual basis. Alternatively, Shell publishes a detailed review of its climate policy engagement every two years, with a detailed update in the interim year.

Has the company disclosed a clear and detailed framework for assessing alignment, including: (1) the criteria it uses to assess whether its climate policy engagement activities (direct or indirect) align with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels; and (2) a clear and detailed explanation behind each evaluation?

Cemex

Cemex has disclosed a methodology for assessing alignment with its industry associations. Alignment is assessed against six of the company’s own climate policy positions including support for: the temperature goals of the Paris Agreement; circular economy policies; policies that encourage the adoption of lower-carbon building materials; support for clean electricity; the implementation of market-based mechanisms such as Emissions Trading Systems (ETS) to regulate CO2 emissions; and government investment in new, innovative decarbonization technologies such as Carbon Capture, Utilization, and Storage (CCUS) to bridge the gap to net-zero in hard to abate sectors.

Cemex states it is committed to “advocate and lobby aligned with the Paris Agreement within the industry trade associations.” Although Cemex explains that it reviews a range of data points for the assessments, the main findings appear to largely focus on its industry associations’ top-line positions rather than detailed advocacy activities. While it does state that its associations have formal positions on circular economy regulations and policies, it does not specify which policies, or detail their positions. Cemex also assessed its industry associations against its own corporate climate policy positions, which appear to be largely limited to top-line positions. As such, Cemex does not appear to have explicitly assessed the alignment of its detailed direct and indirect policy engagement activities against science-aligned policy to deliver the 1.5°C goal of the Paris Agreement.

Cemex has provided information on the levels of alignment for each policy area including ‘Yes’ - Public position is aligned with Cemex, ‘No’ - Moderate misalignment may exist due to advocacy against the Cemex position, and ‘Other’ - Not applicable to the activities of the association; or the association lacks a formal position. However, Cemex has not disclosed what constitutes a finding of overall alignment or misalignment.

Additionally, Cemex has not provided a comprehensive explanation behind the assessment of each industry association.

Best Practice

Unilever assessed its industry associations’ climate policy engagement against both its own climate policy positions, and against science-based policy, determined by “what the Intergovernmental Panel on Climate Change (IPCC) has said is needed to keep global warming below 1.5°C”. Unilever states that this assessment does not mean associations should be expected to support every proposed climate law, but that when an association opposes a specific climate policy, it is incumbent on the association to engage constructively with policymakers to help find alternative, viable policy options that would be (at least) equally effective at reducing emissions.

The company also clearly disclosed the criteria for findings of alignment and misalignment with both its own policy positions and science-based policy, and measured the engagement intensity of each association. It also provided clear and detailed explanations behind each evaluation including their detailed policy positions and links to each industry association’s LobbyMap profile.

Has the company established a clear framework to address misalignments between its climate policy engagement activities (direct or indirect) and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, including the escalation strategies it will use and when it will use these escalation strategies?

Cemex

Cemex has disclosed a framework for addressing potential cases of misalignment with its industry associations, including some escalation strategies. The company stated that, in the case of misalignment, it will increase its engagement in the association to attempt to improve alignment, and if the association repeatedly pursues policies and actions that are contrary to Cemex’s positions, the company will publicly state its disagreement and conduct an internal analysis to determine if rescinding membership may be needed.

However, there are no deadlines attached to this framework for industry associations that do not reform misaligned climate policy engagement practices.

Best Practice

Iberdrola has disclosed a clear and detailed framework to address potential misalignments, including escalation strategies and deadlines for industry associations that do not amend misaligned practices. Iberdrola's escalation strategy includes engagement with the industry association, sending a "notification of dissatisfaction", and formal notification that a termination of membership is being assessed. If the association does not provide a clear and credible action plan to address the misalignment within 12 months, Iberdrola will implement one or more of the following actions: make a clear public statement regarding the misalignment, request the industry association refrains from engaging on misaligned issues, and/or suspension or discontinuation of membership.

Review Assessment (Direct - Company)

Has the company identified and reported on the existence of all misalignments between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database (including all of its subsidiaries, business areas, and operational jurisdictions)?

Cemex

Cemex has committed to align its lobbying and advocacy with the goal of the Paris Agreement of restricting global temperature rise to 1.5°C above pre-industrial levels, however the company does not appear to have actively undertaken a review of the alignment of its own climate policy engagement activities in this document. As such, the company has not identified some cases of direct climate policy engagement that are potentially not aligned with delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.

For example, in March 2024 comments submitted on the policy, Cemex appeared to support the Environment Protection Agency’s (EPA) Label Program for Low Embodied Carbon Construction Materials with some exceptions regarding the lifecycle approach, and the company did not support including recycled content in the program. Cemex also appeared to support carbon capture, utilization and storage technologies (CCUS) in a way that does not appear to be fully aligned with IPCC recommendations in a January 2025 joint letter. The company advocated for the use of CCUS for energy production and manufacturing without mentioning how CCUS can contribute to the transition to a net-zero energy and industrial sector in line with IPCC mitigation pathways.

At the time of this assessment, Cemex’s InfluenceMap organization score was 72%, indicating partial misalignment with science-aligned policy pathways for limiting warming to 1.5°C. Cemex falls just below the threshold for alignment (75%). Please see the Cemex’s profile in the LobbyMap database for additional details on the company's real-world climate policy engagement activities.

Best Practice

Danone assessed 12 of its own climate policy positions and engagement activities across Europe, the US, and globally. It found all 12 to be aligned. According to InfluenceMap’s database, Danone does not appear to have any material evidence of negative climate policy engagement during the reporting period. As a result, Danone has assessed its climate policy engagement activities in line with InfluenceMap’s findings. It is the only company to have ‘broadly met’ the criteria for this indicator.

Sasol published a detailed review of its direct climate policy engagement in August 2023. Sasol assessed the alignment of five of its own climate policy positions, including four in South Africa (Climate Change Bill; Carbon Tax; PCC Just Transition Framework; Upstream Oil and Gas Tax Regime Discussion Document) and one in the EU (European Union Delegated Acts). However, Sasol did not identify any cases of misalignment with its own climate policy engagement. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. The company has not updated its review in 2024.

As a result, no company has shown evidence of identifying cases of misalignment of its direct climate policy engagement and delivering on the 1.5°C goal of the Paris Agreement.

Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?

Cemex

Cemex has not undertaken a review of the alignment of its own climate policy engagement activities. As such, the company has shown no evidence of action to address cases of misalignment between its direct climate policy engagement and science-aligned policy pathways for delivering the 1.5°C goal of the Paris Agreement.

Best Practice

Danone and Unilever are the only companies to have ‘broadly met’ the criteria for this indicator by default. Both companies do not appear to have any material evidence of negative climate policy engagement according to InfluenceMap’s database, and therefore have no cases of misalignment to act upon.

As a result, no company has actively shown evidence of acting to address cases of misalignment between its own direct climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.

Review Assessment (Indirect - Industry Associations)

Has the company identified and reported on the existence of all misalignments between the climate policy engagement activities of its actively engaged industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?

Cemex

Cemex has assessed 14 industry associations and did not identify any cases of misalignment. It did not include key industry associations actively engaged on climate policy within the scope of the review, including Confederation of British Industry (CBI), Corporate Leaders Group (CLG) and Confederación Patronal de la República Mexicana (Coparmex).

InfluenceMap analysis indicates that the company has 0 memberships to industry associations with active climate policy engagement misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database) and at least 4 memberships to industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+). These include Confederation of British Industry (CBI), Portland Cement Association (PCA), European Cement Association (CEMBUREAU), and Confederación Patronal de la República Mexicana (Coparmex).

As Cemex did not identify any cases of misalignment or partial misalignment, it has not identified the above 4 cases of partial misalignment between its industry associations and delivering the 1.5°C goal of the Paris Agreement in line with InfluenceMap’s database.

See Appendix A below for further details on the company’s industry association memberships.

Best Practice

Unilever assessed 27 industry associations in its review and identified all cases of misalignment and partial misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database. Unilever has membership to 1 misaligned industry association (Tennessee Chamber of Commerce & Industry), and 10 partially aligned associations.

Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between the climate policy engagement activities of its industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?

Cemex

Cemex has shown no evidence of action to address specific misalignments with its industry associations. As such, Cemex does not appear to have shown evidence of action to address specific cases of misalignment and partial misalignment with delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.

Best Practice

Unilever is the only company to have met investor expectations in this area, showing evidence of action to address all cases of misalignment between its industry associations and delivering the 1.5⁰C goal of the Paris Agreement, as identified by InfluenceMap’s database. In its review, the company included a section for each association titled “Actions (to be) taken” in which it outlined the actions taken or to be taken with the industry association as per its assessment. For example, Unilever stated that it would write to the Tennessee Chamber of Commerce & Industry stating that their positions do not reflect those of Unilever. It also disclosed it would encourage the European Roundtable for Industry to continue to engage constructively on the EU Green Deal and explore how it can revise its position on the EU Emissions Trading System.

Additionally, Unilever stated that for the 12 associations that were deemed “passively aligned” (minimal to non-existent policy engagement), the company will aim to push the associations to become more actively engaged in promoting outcomes and policies that aid in decarbonization.

Key

Yes, meets criteria

Partial, meets some criteria

No, does not meet criteria

Appendix A: Cemex's Industry Association Memberships

The table below provides a ranking of Cemex's industry associations currently covered by InfluenceMap’s database by Performance Band, i.e. a full measure of a company’s climate policy engagement, accounting for both its own engagement and that of its industry associations. Detailed profiles for all industry associations can be explored via the links in the table.

Industry associations are categorized by InfluenceMap as having climate policy engagement that is aligned, partially misaligned or misaligned with delivering the 1.5°C goal of the Paris Agreement by Performance Band:

  • Aligned = Performance Band A+ to B
  • Partially Misaligned = Performance Band B- to D+
  • Misaligned = Performance Band D to F
  • Low Engagement = Performance Band N/A

The ranking table below is updated automatically on a continual basis as: (1) new evidence is collected for the industry associations; (2) new industry associations are added to the company profile; (3) industry associations are removed from the company profile, e.g. if the company leaves the association.

As such, the industry associations and/or scores in the ranking table below may differ from the findings in Identify & Assess (Indirect) above, which was written on the date of assessment. See the top of this page for the date of assessment.

Industry AssociationInfluenceMap Performance BandInfluenceMap Assessment
Corporate Leaders Group (CLG)A-Aligned
Confederation of British Industry (CBI)B-Partially Aligned
Global Cement and Concrete AssociationCPartially Aligned
Cámara Nacional del Cemento (CANACEM)C-Partially Aligned
Portland Cement Association (PCA)C-Partially Aligned
Confederación Patronal de la República Mexicana (Coparmex)D+Partially Aligned
European Cement Association (CEMBUREAU)D+Partially Aligned