Eni SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Eni SpA has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly named specific climate policies it has engaged with, including the European Emission Trading Scheme (EU-ETS), the EU Regulation on methane emissions reduction, and the certification of carbon removals under EU rules. Eni also disclosed its engagement with the UK Government's Department of Energy Security and Net Zero (DESNZ) on the HyNet North West industrial CCS cluster and its plans for a second UK CCS hub. Additionally, Eni has participated in public consultations on policies such as 'Updating the EU ETS,' 'New rules to prevent methane leakage in the energy sector,' and 'Sustainable aviation fuels – ReFuelEU Aviation,' demonstrating transparency in identifying the policies it has lobbied. The company provides detailed information about its lobbying mechanisms and targets, including direct engagement through meetings, round tables, and public consultations with entities such as the European Commission, DESNZ, and international organizations like UNEP and IRENA. Eni also engages indirectly through trade associations like the Oil and Gas Climate Initiative (OGCI) and the International Association of Oil and Gas Producers (IOGP), ensuring alignment with its climate principles. Furthermore, Eni has been explicit about the outcomes it seeks through its lobbying efforts, such as achieving near-zero methane emissions by 2030, supporting the EU's methane emissions reduction law, and advocating for harmonized rules on carbon removal certification to scale up investments in the carbon removal market. The company also aims to establish infrastructure for CO2 transportation and storage, contributing to the decarbonization of industrial activities in the UK and supporting local jobs and investment. These disclosures illustrate Eni's comprehensive approach to climate lobbying transparency, aligning its efforts with measurable policy goals and its commitment to achieving net-zero emissions by 2050.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Eni demonstrates a comprehensive governance process for climate lobbying alignment, as evidenced by its detailed methodology for assessing the alignment of business associations with its climate-related advocacy. The company conducts biannual assessments to ensure alignment between the positions of business associations and Eni's principles on climate-related topics, stating, "In accordance with the policy on the Eni's responsible engagement on climate change within business associations, every 2 years we conduct an assessment to check the alignment between the business association positions and the Eni's principles on climate-related topics." This process is coordinated by the Climate Change Strategy and Positioning Department, which drafts a preliminary position that is reviewed by operational business units, including the Legal Department and the Office of the CEO, to finalize the position. "The process is coordinated by the Climate Change Strategy and Positioning Dpt. at corporate level, which drafts a preliminary position. Afterwards, the draft is submitted to the operational Business Unit, including Legal Dpt and Office of the CEO, to collect their feedback (amendment or additions)." Eni also reviews publicly available data to assess alignment and categorizes associations as 'aligned,' 'partially aligned,' or 'not aligned,' and engages with representatives and management of associations to influence their positions or evaluates membership renewal in cases of misalignment. "In case any misalignment still stands, we put forward actions aimed at influencing each entity's positions towards more positive lobbying vision (case of partially misalignment) or we evaluate to not renew our membership (case of deep misalignment)." Furthermore, Eni has published assessments on its website, with the latest one in May 2022, and has created a dedicated webpage summarizing its advocacy activities, including contributions to public consultations and submissions to authorities. "The first assessment has been published on the Eni website in 2020 and last one in May 2022. Moreover, to increase our visibility and transparency towards stakeholders, we also published a new page on our website, where we recap our advocacy activities in favour of climate issues." Additionally, Eni has identified responsible parties for overseeing climate lobbying alignment, such as its climate strategy department and board of directors, and has committed to proactive engagement with partially aligned associations to influence their positions positively. "Within the business associations which have been evaluated as partially aligned, Eni will proactively engage with other members in order to drive and influence each entity's positions towards a more positive lobbying vision." This comprehensive approach, including detailed assessments, proactive engagement, and clear accountability structures, indicates strong governance and transparency in climate lobbying alignment.	4