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| Overall Assessment |
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| Comprehensive |
TotalEnergies SE has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has explicitly named specific climate policies and regulations it has engaged with, such as the "European Green Deal," the "EU emissions trading system (ETS) and its Innovation Fund rules," and "methane regulation" focused on "methane emissions." It has also disclosed its advocacy actions related to the "Renewable Energy Acceleration Bill in France" and the "Inflation Reduction Act (IRA)" in the United States, providing detailed insights into its lobbying activities. TotalEnergies has been clear about its lobbying mechanisms, including direct participation in consultations, such as those with the European Commission on renewable energy projects and the U.S. Senate on regulatory frameworks for LNG and biofuels. The company also detailed its advocacy through public consultations, letters to policymakers, and participation in legislative discussions, such as its engagement with the French HATVP register and its advocacy actions towards EU institutions. Furthermore, TotalEnergies has outlined specific policy outcomes it seeks to achieve, such as simplifying and accelerating the permitting process for renewable energy projects, advocating for regulatory changes to create a more supportive framework for combined technology power plants, and opposing the "projected lowering of regulatory requirements on methane emission control in the oil and gas industry." These disclosures reflect a high degree of transparency in naming the policies, mechanisms, and desired outcomes of its lobbying efforts.
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4
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
TotalEnergies demonstrates a comprehensive governance process for climate lobbying alignment, particularly through its detailed trade association reviews conducted biennially. The company has published its "2023 Review of Industry Associations," which includes an assessment of 116 associations against six key climate-related principles, such as recognizing the Paris Agreement and supporting carbon pricing mechanisms. The review explicitly mentions that "TotalEnergies conducts regular assessments of the public positions of the industry associations to which we belong, ensuring continued alignment with our principles on climate-related topics." Furthermore, the company has disclosed its methodology, assessment criteria, and findings, including categorizing associations as aligned, partially aligned, or not aligned based on their climate positions. For example, "In 2023, we assessed the climate positions of 116 key associations against our six key principles on climate-related topics and we found 114 associations to be aligned and 2 partially aligned." TotalEnergies also provides transparency by listing the associations it supports, along with membership fees and activities, ensuring accountability and alignment with its climate goals. Additionally, the governance process is overseen by corporate-level entities, as evidenced by the consolidation of membership information from over 1,000 organizations worldwide. The company has also taken proactive actions, such as withdrawing from the American Petroleum Institute (API) due to "persistent differences" in climate positions, demonstrating its commitment to enforcing alignment. This indicates a robust governance framework that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms and accountability structures in place.
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4
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