Approved by the President of Stock CO₂ (October 2026). Reviewed every year by the President.
1. Purpose and scope
By lobbying, we mean any action aimed at influencing a public decision, a law, a regulation or a market standard: exchanges with elected officials, government bodies or European and international institutions, responses to public consultations, publication of position papers, and actions carried out through associations we belong to.
Our interest representation activity is currently as follows:
- Nature+ Coalition: Stock CO₂ has been a founding member since October 2025, and Guillaume Panthou-Brochard, co-founder of Stock CO₂, is its Vice-President. The coalition, a French non-profit association (loi 1901), advocates for high-integrity nature-based solutions in European and international climate policy: Article 6 of the Paris Agreement, the EU carbon removals certification framework, the EU 2040 climate target, and voluntary market standards. Stock CO₂ designs and maintains the coalition's digital platform pro bono (public website, members' area, board and secretariat tools); only legal costs incurred on the coalition's behalf are recharged to it.
- Association Française des Eaux et Forêts (AFEF): Aubin Labergère-Laroche, co-founder of Stock CO₂, is its Secretary General. AFEF brings together forestry stakeholders; it carries out little advocacy.
- Public positions: Stock CO₂ publishes position papers on its website on responsible carbon contribution, biodiversity in forestry projects, extra-financial reporting (CSRD) and its method for assessing project impact.
Our responses to public tenders are not lobbying. They follow the rules of the French public procurement code: during a procedure, we only communicate with the buyer through the channels it has provided.
2. Our commitments
a) Lobbying in the public interest. We only advocate positions that contribute to climate change mitigation, consistent with the 1.5 °C goal, and to the preservation of biodiversity, water and soils. We never seek to weaken an environmental or social rule, even if it constrains us. When our commercial interest is at stake, we say so.
b) Fact-based positions. Our positions rely on verifiable data: scientific publications, public data, official standards such as the Label Bas-Carbone, and data from our own projects. We cite our sources and flag uncertainties. We publicly correct a position whose data turns out to be wrong.
c) No political contributions. Stock CO₂ makes no financial or in-kind contribution to any party, political movement, candidate or election campaign, in France or abroad. It provides them with no staff, premises or services. Our employees remain free in their personal involvement; it is never carried out in the name or at the expense of Stock CO₂.
d) Anti-corruption. We do not offer, promise or accept, directly or through a third party, any advantage intended to obtain a favourable decision. We do not offer any public official or elected representative any gift or invitation worth more than €100. Any conflict of interest, actual or apparent, is declared to the committee. Stock CO₂ is not registered in the register of interest representatives of the French High Authority for Transparency in Public Life (HATVP), because it does not fall within the scope of this obligation; the policy lead checks each year that this is still the case and registers if the situation changes.
e) Lobbying through our associations. When we act within an association or coalition, we check that its positions are compatible with this policy. Each year, the President reviews the organisations we belong to, the positions we hold in them and their main public positions. In case of disagreement, we make it known within the organisation, we do not sign the position concerned and, if the disagreement persists on an essential point, we leave the organisation. Our positions within these organisations are public.
| Organisation | Link with Stock CO₂ |
|---|---|
| Nature+ Coalition | Founding member; vice-presidency (Guillaume Panthou-Brochard); pro bono design and maintenance of the coalition platform |
| AFEF | Secretary General (Aubin Labergère-Laroche) |
f) Approval. This policy is approved by the President of Stock CO₂, PANTHOU Gestion, represented by Guillaume Panthou-Brochard. The President reviews it every year.
3. Governance
- Lead: Guillaume Panthou-Brochard, co-founder of Stock CO₂. He keeps the list of interest representation actions and of the organisations Stock CO₂ belongs to, and presents it to the President each year.
- Integration within the company: the policy is given to every employee and every executive who represents Stock CO₂ externally. Any position published in Stock CO₂'s name is reviewed by a second executive before release, in light of this policy and our responsible communication rules.
- Non-compliance risks: we have identified three main risks: an association position contrary to our commitments, a conflict of interest between an association role and Stock CO₂'s commercial activity, and an unsubstantiated claim in a publication.
- Monitoring: during the annual review, the President examines the list of actions and memberships, the year's public positions and any reports received. The conclusions are recorded in the President's decision.
- Reporting: anyone, internal or external, can report a breach of this policy through Stock CO₂'s complaints procedure. No retaliation is taken against anyone who reports in good faith.