A new Social LobbyMap briefing examines the October 2025 Franco-German Evian letter—and finds its claim to represent a room full of CEOs didn’t hold up to scrutiny.
In October 2025, a letter signed by the CEOs of TotalEnergies SE and Siemens AG landed on the desks of President Macron and Chancellor Merz. It called for the “full abolishment” of the Corporate Sustainability Due Diligence Directive (CSDDD) and claimed to speak on behalf of all 45 CEOs who had attended the annual closed-door Franco-German meeting in Evian.
Our new briefing examines what the data actually shows.
Of the 45 entities present at the meeting, only 2 signed the letter and 2 more later endorsed it. 13 publicly distanced themselves. 28 made no public statement—and when we engaged with all 45 entities, 4 of those 28 volunteered to us that the call for “full abolishment” did not reflect their values, a position they had not stated publicly. No company responded proactively: every public response came only after outreach from journalists or civil society, including from Social LobbyMap.
When we assessed the 21 entities with publicly traceable lobbying positions in our database, a majority supported mandatory human rights due diligence in principle. The picture is more mixed across broader CSDDD indicators, but it is far from the consensus presented in the letter.
The briefing also applies the UN Guiding Principles on Business and Human Rights to this situation, arguing that companies linked to a letter calling for the abolition of human rights due diligence legislation have a responsibility to respond publicly—and that this responsibility remains even where companies had no opportunity to influence the letter’s content.
It situates the Evian letter within the wider pattern of low-transparency corporate lobbying on the CSDDD, including the Competitiveness Roundtable uncovered by SOMO.
Our targeted recommendations for policymakers, investors, companies, and civil society on how to respond to similar cases in future:
For policymakers:
> In cases like the Evian letter, where positions are put forward collectively or on behalf of others, caution should be applied before treating them as genuine industry consensus in the absence of individual company sign-on or public endorsement;
> Where positions lack clear governance, question how they were developed and how support was secured;
> Be aware of the risks associated with conducting policy consultations in the form of conferences or group meetings, as the positions presented by the speakers may not be representative of all the entities in attendance.
For investors:
> Be aware of the valuable role investors play when a situation like this occurs and be ready to use it confidently. Investors have access and leverage with companies and can request clarifications and public responses;
> Understand and require transparency on the positions held by investee companies, including those who have remained silent in this case. Less than half of the companies listed on the Evian letter responded publicly; and of those that did, all did so retroactively rather than proactively;
> Promote internal coordination, consistency and alignment of policy positions among the corporates engaged with as part of good governance. In cases such as this and as human rights due diligence regimes evolve, potential internal corporate misalignment presents material governance, reputational, and regulatory risk;
> Make use of available data and guidance on engagement. These include the Social LobbyMap platform as well as Principles for Responsible Investments’ (PRI’s) investor guidance on responsible political engagement.
For companies:
> Recognise the reputational risk that can accompany public perception of behind-the-scenes lobbying activity;
> Address this risk through rigorous governance of corporate activity, aligning departments overseeing the company’s human rights commitments and responsibilities with its public affairs activities. Internal communication and consistency can ensure the company advocates ethically and constructively for its interests, avoiding the pitfalls of lobbying against social positions it has otherwise publicly committed to in the public perception of a company;
> Treat the role of the CEO as vital and ensure it is taken seriously, as CEOs are perceived as mouthpieces of the company and as representing the company’s values and positions. Ensure CEOs are briefed on the commitments and positions held by the company prior to attending networking events. This should include raising awareness of potentially contentious issues and conflicting agendas of representatives from other companies in attendance. CEOs themselves should be alive to the risks of collaborative access to policymakers, and prepared to intervene with peers where necessary;
> Speak out publicly when they do not align with positions being presented on their behalf (whether through formal trade associations or more informally as in the case of the Evian letter) and advocate for greater transparency on how group policy positions are being determined;
> Publicly disclose their lobbying positions when engaging with policymakers. Where closed-door meetings take place, detailed minutes and accurate reflections of the conversations should be made publicly available in a timely manner.
For CSOs:
> Be ready to hold corporate entities accountable for oppositional lobbying aimed at the weakening of social standards, such as the entities that signed and publicly aligned with the call to abolish the CSDDD;
> Challenge positions that are presented as supposed industry consensus, as was the case with the Evian letter, by making use of SLM data on misalignment when conducting advocacy with policymakers;
> Use your connections and engagement with companies to promote and amplify supportive and consistent approaches to policy positions, including those who have come out in opposition to the Evian letter’s call to abolish the CSDDD;
> Encourage investors to understand and use their leverage over investee companies to request public responses, encourage progressive political engagement, and promote internal corporate alignment.