Direct Lobbying Transparency
| Overall Assessment | Comment | Score |
|---|---|---|
| Strong | TUI AG provides a relatively detailed picture of its climate-policy advocacy. It explicitly identifies the measures it engages on, naming the “EU Emissions Trading Scheme,” the “UK Emissions Trading Scheme” and the “EU Monitoring, Reporting and Verification (MRV) legislation for shipping,” and reports that it has “continued to support the inclusion of aviation emissions in the EU and UK ETS.” The group also explains how it seeks to influence policy: it maintains “open dialogue with decision-makers in Berlin, Brussels and in the destinations,” and it pursues indirect lobbying through TUIfly’s membership of the German Aviation Association (BDL), which works on the future environmental framework for aviation—clearly identifying both direct engagement with national and EU institutions and association-based advocacy. Finally, TUI sets out the concrete outcomes it is trying to achieve, backing the extension of the ETS to aviation and endorsing MRV rules that “require shipping companies to monitor and report the verified amount of CO2 emitted by their vessels.” Together, these disclosures show strong transparency on which climate policies it targets and the positions it advances, although the company gives fewer operational details about the specific formats of its engagements than the most comprehensive reporters. | 3 |