Thyssenkrupp AG

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Thyssenkrupp AG has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly named specific climate policies it engaged with, including the "EU Emissions Trading System (EU ETS) and Carbon Border Adjustment Mechanism (CBAM)," "EU hydrogen and decarbonised gas package," "Revision of the Renewable Energy Directive," and the "National climate bill - German climate protection bill (Klimaschutz-Sofortprogramm)." Additionally, it referenced its involvement in the "Climate Protection Act 2021" and other initiatives such as "Fit for 55" and "Germany's national hydrogen strategy." Thyssenkrupp has disclosed both direct and indirect lobbying mechanisms, stating that it was "involved both directly and through its trade associations by providing input to and feedback on the legislative proposals of the European Commission." It also identified specific targets of its lobbying efforts, such as the European Commission and the German government, ensuring clarity in its engagement approach. Furthermore, the company has been transparent about the specific policy outcomes it seeks, advocating for "free allocations [to] be kept at reasonable levels reflecting technology levels until 2030 for companies that invest in climate neutral production processes" and opposing the unbundling of gas and hydrogen distribution activities under one company after 2030. Thyssenkrupp also supports "an increase of the EU's renewable energy targets" and prioritizing hydrogen access to sectors with the highest CO2 abatement potentials. These detailed and measurable outcomes reflect a clear intent to influence policy and demonstrate a high level of transparency in its climate lobbying disclosures. 4
Lobbying Governance
Overall Assessment Comment Score
Strong TK Elevator (TKE) demonstrates a strong governance process to ensure alignment of its climate lobbying activities with its overall climate change strategy. The company states that "our climate targets are communicated top-down to the Business Units (BU) of TKE, which shall align their engagement initiatives and other local activities to our global approach," indicating a structured approach to alignment. TKE has identified responsible parties for overseeing this alignment, noting that "every BU has a BU Coordinator who monitors the progress of our climate targets and KPIs, and coordinates all engagement initiatives and other local activities in line with the global targets." Furthermore, the evidence describes a monitoring process, as the BU Coordinators are tasked with ensuring that engagement activities are consistent with the company's climate change strategy. Additionally, TKE provides an example of indirect lobbying alignment, stating that "our Business Unit Europe Africa engaged in the development of an Ecodesign Preparatory Study for the Ecodesign Directive (Directive 2009/125/EC) leaded by the European Commission. In this case the engagement was done directly with the policy makers, the European Commission, and indirectly through trade associations and was coordinated internally by the BU Coordinator with our overall climate change strategy." This indicates strong governance with clear oversight structures and monitoring mechanisms in place. 3