Neste Oyj

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Neste provides a highly transparent picture of its climate-policy advocacy. It names multiple, identifiable pieces of legislation it works on, including the EU’s Fit for 55 package and its component Renewable Energy Directive II and III revisions, EU-wide Sustainable Aviation Fuel blending mandates, the development of definitions and rules for green and low-carbon hydrogen, national SAF blending obligations in Norway and Sweden, and the continuation of Finland’s CO2-based fuel-tax system. The company also explains how it engages: it takes part in public consultations, holds meetings, conducts stakeholder dialogues and site visits, and works through trade associations, while targeting specific interlocutors such as “EU decision-makers and Member States,” “policy makers within ICAO,” and national governments. Finally, Neste is explicit about the outcomes it is pursuing—advocating “higher ambition in decarbonising the transport sector,” enlarging “the sustainable raw material pool for biofuels,” easing restrictive RFNBO rules to unlock investment in green hydrogen, clarifying rules for novel vegetable oils to maximise GHG savings, supporting SAF as a “drop-in solution to cut aviation GHG emissions,” and, as it puts it, “We support that the fuel CO2 tax model is continued.” By spelling out the specific measures it lobbies on, the methods it uses, and the concrete policy changes it seeks, Neste demonstrates a comprehensive level of transparency on its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Neste provides moderate governance of its climate lobbying by embedding its climate strategy into engagement activities and naming a clear oversight role, but detailed monitoring or broader governance structures are not described. For example, “Senior Vice President, Sustainability and Corporate Affairs at Neste is responsible for both Public Affairs and Sustainability at Neste, ensuring our activities within both functions are aligned,” and “In the beginning of each engagement with policy-makers, trade associations or other organization, Neste presents our position on climate change and our climate commitments as part of the company presentation.” The company also confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” through its signature of the Business Ambition for 1.5°C Commitment Letter. However, we found no evidence of a formal monitoring or review procedure for lobbying activities, no systematic process to manage indirect lobbying through trade associations or assess association membership, and the company does not disclose any Board-level oversight or detailed policy for climate lobbying alignment beyond the SVP role.	2