Ecopetrol SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Ecopetrol SA provides a highly detailed picture of its climate-policy lobbying. It names a wide range of specific Colombian measures it has engaged on, including the CONPES “Energy Transition Policy,” the “Integral Climate Change Plan of the Mines and Energy sector” (Resolution 40807), draft decrees amending the carbon-tax provisions of Decree 1076/2015 and regulating Carbon Capture, Use and Storage under Law 2099/2021, the design of the national cap-and-trade system (PNCTE), Resolution 40066/2022 on methane, the 2169 Law of 2021, ANH’s Open Area Nomination Process – PANA, and a draft resolution on verification of GHG-mitigation initiatives, leaving little doubt about which policies it seeks to influence. For each of these files the company sets out the methods it used and whom it approached: it “participated in technical round tables for consultation,” joined “construction workshops,” “provided corporate information for the sectorial baseline,” lodged comments in a “participative regulatory process,” and engaged directly with identified authorities such as the Ministry of Mines and Energy, the Ministry of Environment and Sustainable Development and the National Hydrocarbons Agency. Ecopetrol is equally explicit about what it wants from these engagements. It backs the Energy Transition Policy “without exceptions” to drive national energy transformation, supports lowering the carbon-tax neutralisation limit while safeguarding “reduction projects funding” and “carbon neutrality declarations,” presses for “the promotion, implementation and development of CCUS technologies” with robust measurement and verification rules, advocates adding a “carbon management chapter” with direct- and indirect-emission requirements to the ANH process, and calls for clear criteria for validation and verification of mitigation initiatives. By specifying the policies, the mechanisms and the concrete outcomes it pursues, the company demonstrates a comprehensive level of transparency around its climate lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Ecopetrol SA demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate change. The company ensures alignment of its climate-related policy efforts with its 2040 Corporate Strategy and environmental strategy, which includes a Climate Change Pillar with an action line for "participation in public policy documents," establishing revision and compliance mechanisms for climate-related legislation and policy. Additionally, the strategic risk "Inadequate management of climate change and water" includes a Key Risk Indicator (KRI) to monitor and analyze legislative projects affecting climate and water issues, which serves as a mechanism to align policy actions with the company's overall strategy. Oversight of climate-related risks and opportunities is provided by the Board of Directors, which defines and oversees the Corporate Strategy, including TESG drivers and climate change. Various committees, such as the Audit and Risk Committee, Corporate Governance and Sustainability Committee, and HSE Committee, address climate-related issues, including methane reduction targets and water neutrality roadmaps. However, while these structures indicate a process for monitoring and aligning climate-related activities, there is no explicit evidence of a detailed governance framework for lobbying alignment, nor is there a public commitment to conduct engagement activities in line with the Paris Agreement goals. The company does not disclose specific mechanisms for managing indirect lobbying through trade associations or industry bodies, nor does it provide evidence of a recurring audit or review process for lobbying alignment.	2