This scorecard provides a detailed breakdown of InfluenceMap's assessment of Heidelberg Materials'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 Heidelberg Materials, 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:
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 Heidelberg Materials's company profile - is accessible via the buttons on the right hand side of the page.
A summary of Heidelberg Materials'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.
| Indicator | Score |
|---|---|
| Accuracy of Climate Policy Engagement Disclosure | Partial, meets some criteria |
| Sub-Indicator | Score |
|---|---|
| Accuracy of Direct Climate Policy Engagement Disclosure | Yes, meets criteria |
| Accuracy of Indirect Climate Policy Engagement Disclosure | No, does not meet criteria |
A summary of Heidelberg Materials'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 Review | Score |
|---|---|
| December 2022 | 5/14 (36%) |
| December 2023 | 5/14 (36%) |
| February 2025 | 3/14 (21%) |
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 Heidelberg Materials'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)?
Heidelberg Materials has published a broadly complete account of its positions and engagement activities on specific climate-related policies, but appears to exclude 1 case of material evidence of direct climate policy engagement identified by InfluenceMap's database.
In its 2024 Climate Advocacy and Association Review, the company provided details of its entries in the EU and German transparency registers, and disclosed its positions on industry decarbonization and specific climate-related policies, including the EU Carbon Border Adjustment Mechanism.
However, Heidelberg Materials does not appear to have disclosed a January 2025 joint letter to U.S. policymakers, in which signatories opposed the rollback of specific CCUS incentives in the U.S. Inflation Reduction Act, however without clearly aligning their position with IPCC guidance on the role of CCUS in the energy transition.
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)?
Heidelberg Materials has disclosed a partial list of its industry association memberships, but appears to exclude 5 industry associations which are actively engaged on climate policy, the Federation of German Industries (BDI), the Business Council of Australia, the German Chemical Industry Association (VCI), the Spanish Confederation of Business Organizations (CEOE), and the European Union Chamber of Commerce in China.
Additionally, the company's disclosure on its industry associations is limited to top-line climate statements without reference to specific climate policies. Heidelberg has therefore excluded key instances of engagement with specific climate-related policies by its industry associations.
For example, CEMBUREAU supported the EU Low Carbon Hydrogen Delegated Act with major exceptions in October 2024. In January 2025, the Portland Cement Association opposed the rollback of CCUS incentives in the US Inflation Reduction Act.
See Appendix A below for details of the company's industry association memberships.
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.
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 Heidelberg Materials's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.
| Review Process | Review Assessment (Direct) | Review Assessment (Indirect) |
|---|---|---|
| Monitor & Review | Identify & Assess | Identify & Assess |
| Alignment Assessment Method | Act | Act |
| Framework for Misalignment |
The tables below provide: (1) a breakdown of Heidelberg Materials'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 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?
In its 2023 review, the company stated its commitment to publish annual reviews of its industry associations’ corporate climate advocacy. However, InfluenceMap research suggests it did not publish a review in 2024. Its most recent review was published in March 2025.
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?
Heidelberg Materials has disclosed a methodology to assess the alignment of its industry associations. The company states that it assessed whether its associations fully support the Paris Agreement, and if they align on policies that support meeting the company’s own climate targets (net-zero by 2050). It also provided 6 additional criteria for assessing cement associations: (1) aligned with the Paris Agreement; (2) have a corresponding CO2 roadmap; (3) advocate for (the introduction of) carbon pricing; (4) advocate for the support of advanced technologies, e.g. CCUS; (5) advocate for the support of low-carbon products; and (6) advocate for the support of renewable energies. In addition, Heidelberg Materials has provided information on what constitutes a finding of ‘Fully aligned’, ‘Partially misaligned’, and ‘Misaligned’.
Heidelberg Materials states that it has assessed whether an association’s lobbying is aligned with the goals of the Paris Agreement, however it provides no further details on how this was carried out. Similarly, it does not detail how it assessed whether its associations algn on policies that support meeting the company’s own climate targets. The rest of the assessment covers its cement associations’ ‘alignment’ to the remaining high-level climate policy positions outlined above. As such, it is not clear that Heidelberg Materials has assessed its associations’ detailed climate policy engagement activities against science-aligned policy pathways for delivering the 1.5°C goal of the Paris Agreement.
The company provided a table that identified alignment with each criterion for each association, and therefore identified which association were aligned. However, the company did not provide clear and detailed explanations behind each evaluation.
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?
Heidelberg Materials has disclosed a clear framework to address misalignment with its industry associations, including escalation strategies. The company stated that if it finds misalignment with an industry association, it will increase its engagement with association committees and signal its dissent to improve alignment or to demand the association not take a position. Heidelberg Materials also states that if misalignment persists, the company will make its disagreement public, assess the association’s performance and membership value, and review if exiting the association is appropriate.
However, the company did not include clear deadlines for associations that do no amend misaligned practices.
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.
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)?
Heidelberg Materials states that it advocates for “policy frameworks that are aligned with our own climate ambition and targets and meet the goals of the UNFCCC Paris Agreement.” However, it has not undertaken a review of the alignment of its own climate policy engagement activities. As a result, the company has not identified any cases of potential misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
For example, Heidelberg Materials’ position on the energy transition and decarbonization has been unclear in some instances. In July 2024 the company signed the Oslo Declaration, which stated support for a ‘technology-neutral’ approach to the energy transition. Additionally, in a March 2025 submission to the German Lobbying Register, the company expressed an unclear position on the role for carbon capture and storage (CCUS) in the broader energy transition outside of cement decarbonization, without clearly communicating timescales and use cases in line with IPCC guidance.
At the time of this assessment Heidelberg Materials' InfluenceMap organization score was 59%, indicating partial misalignment with policy pathways for delivering the 1.5C goal of the Paris Agreement. Its Engagement Intensity metric was 27%, indicating strategic engagement on climate policy with a mix of positive and negative positions. Please see Heidelberg Materials' profile in the LobbyMap database for additional details on the company's real-world climate policy engagement activities.
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?
Heidelberg Materials has not undertaken a review of the alignment of its own climate policy engagement activities. As a result, the company has shown no evidence of action to address cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement.
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.
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?
Heidelberg Materials assessed 26 associations in its review. However, the company excluded key industry associations actively engaged on climate policy within the scope of the review, including the Federation of German Industries (BDI), where it holds board membership, and the Spanish Confederation of Business Organizations, where its CEO is the head of the Comisión de Unión Europea.
In its review, the company found 16 associations to be fully aligned, 9 partially misaligned, and 1 misaligned (Chamber of Cement Manufacturers Ghana (COCMAG)). None of the associations it identified misalignment/partial misalignment with are currently covered by InfluenceMap’s database.
InfluenceMap analysis indicates that Heidelberg Materials has at least 2 membership to an industry association 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); the German Chemical Industry Association (VCI), and Spanish Confederation of Business Organizations (CEOE). InfluenceMap analysis also indicates the company has 5 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+).
The company did not identify misalignments with industry associations identified by InfluenceMap to be actively engaged on climate policy, and misaligned or partially misaligned with delivering the 1.5°C goal of the Paris Agreement. See Appendix A below for further details on the company’s industry association memberships.
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?
Heidelberg Materials 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.
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.
Yes, meets criteria
Partial, meets some criteria
No, does not meet criteria
The table below provides a ranking of Heidelberg Materials'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:
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 Association | InfluenceMap Performance Band | InfluenceMap Assessment |
|---|---|---|
| European Union Chamber of Commerce in China | C+ | Partially Aligned |
| Cement Manufacturers’ Association (CMA) India | C+ | Partially Aligned |
| Global Cement and Concrete Association | C | Partially Aligned |
| Business Council of Australia | C- | Partially Aligned |
| Portland Cement Association (PCA) | C- | Partially Aligned |
| European Cement Association (CEMBUREAU) | D+ | Partially Aligned |
| Federation of German Industries (BDI) | D+ | Partially Aligned |
| Spanish Confederation of Business Organizations (CEOE) | D | Misaligned |
| German Chemical Industry Association (VCI) | D | Misaligned |
