LUKOIL PJSC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	LUKOIL provides an unusually detailed picture of its climate-policy advocacy. It names a wide range of specific measures it engaged on, including implementation of Article 6 of the Paris Agreement, the National Low-Carbon Development Strategy, the Ministry of Energy’s scheme for low-carbon electricity certificates, the national Adaptation Plan, the creation of a national GHG-regulation system with emissions pricing, and development of a Russian Green Taxonomy. The company also explains how it lobbied and whom it approached, citing the preparation of an official position through the Russian Union of Industrialists & Entrepreneurs “directed to government agencies,” sending “proposals… to the Ministry of Economic Development,” ongoing “cooperation with the Russian Ministry of Economic Development and Trade,” interaction with the Government of the Russian Federation on GHG regulation, and direct engagement with the taxonomy’s developers. Finally, it is explicit about the policy outcomes it seeks: it backs a mechanism for certificates “as an additional tool to support renewable energy in Russia,” advocates “the introduction of a pricing factor for GHG emissions… to stimulate the implementation of low-carbon solutions,” asks that support schemes include projects that reduce greenhouse-gas emissions, and proposes forecasts and pathways for the fuel and energy complex to 2035. By clearly linking each policy area to specific lobbying actions and desired results, LUKOIL demonstrates a comprehensive level of transparency around its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	LUKOIL PJSC indicates a public commitment to “conduct your engagement activities in line with the goals of the Paris Agreement,” which shows a stated intention to align its advocacy with climate objectives. However, the company does not disclose any formal governance process or specific oversight body to manage or review its lobbying activities against this commitment. We found no evidence of a named individual or committee responsible for approving lobbying positions, no description of how direct or indirect lobbying is monitored or managed, and no policy outlining criteria for assessing trade associations or external advocacy in line with the Paris Agreement goals, indicating only limited governance on climate-related lobbying alignment.	1