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| Overall Assessment |
Comment |
Score |
| Comprehensive |
E.ON SE has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly identifies multiple specific climate policies it has engaged with, including the EU Emissions Trading Scheme (EU-ETS), the EU Green Deal, the "Fit for 55" legislative package, the Fuel Emissions Trading Act (BEHG) in Germany, and the "Clean Energy for All Europeans" proposals. It provides detailed information about its lobbying mechanisms, such as direct lobbying through speeches and talks with politicians and journalists by its CEO, indirect lobbying through associations like Eurelectric and Wind Europe, and participation in coalitions such as "Friends of the ETS" and the CEO Alliance. The company also specifies its lobbying targets, including the European Commission, European Council, and European Parliament, as well as federal and state-level institutions in Germany. Furthermore, E.ON SE outlines clear and specific policy outcomes it seeks to achieve, such as advocating for structural reforms to the EU-ETS, introducing a minimum carbon price, sending strong carbon pricing signals, accelerating decarbonization measures across sectors, and achieving carbon neutrality by 2050. These disclosures reflect a high degree of transparency in naming policies, mechanisms, targets, and desired outcomes, aligning its lobbying efforts with ambitious climate goals and the Paris Agreement.
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4
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
E.ON demonstrates a comprehensive governance process for climate lobbying alignment, showcasing a detailed and proactive approach to ensuring consistency with its climate change strategy. The company has conducted an in-depth analysis of its engagement activities, stating, "We listed 56 initiatives, organisations and associations, compared their positions to ours, and evaluated whether these are aligned, partially (mis)aligned, misaligned – or whether there is no position," which highlights a thorough review of both direct and indirect lobbying efforts. E.ON has also outlined a clear policy for addressing misalignment, emphasizing, "Within 2022, we will go into dialogue with the associations in misalignment. We will address the reasons for non-conformance and scrutinise the possibility on their side to rework their positions. Should their positions not change or permanently contradict our positions, we will challenge the continuation of those memberships." This demonstrates a proactive stance in ensuring alignment with climate goals. Transparency is further enhanced through the "E.ON Climate Advocacy and Associations Report," which covers 56 memberships relevant to climate advocacy and includes positions on key climate-related topics such as the Paris Agreement and carbon pricing. E.ON plans to "regularly publish an updated version of this document and demonstrate our efforts in continuously reviewing our alignment with the political stakeholders we engage with and fostering transparency." Additionally, the governance process is supported by close coordination with international units to ensure updates and alignment, as stated: "We have selected the most important global, European and national organisations for the topic of climate protection and are in close contact with our international units to ensure continuous update of our involvement in associations and initiatives." This indicates robust monitoring mechanisms and accountability structures, fulfilling the criteria for a comprehensive governance process.
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4
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