OCI NV

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	OCI NV provides extensive and specific information on every dimension of its climate-policy lobbying. It lists multiple named measures it has engaged on, including the EU Emissions Trading System, the Carbon Border Adjustment Mechanism, the Dutch Climate Tax, the U.S. Inflation Reduction Act, and "proposed new carbon dioxide emissions regulations and additional taxes" in the Netherlands, as well as broader frameworks such as the Paris Climate Agreement and national cap-and-trade proposals. The company is equally explicit about the way it seeks to influence these policies, describing a variety of direct and indirect channels—"responding to consultations," "submitting public comments and in meetings with regulators with our industry associations," "ongoing dialogue with [the] Dutch government," and having "signed a non-binding Expression of Principles with the Dutch Government and the provinces of Limburg and South Holland." It names the public-sector counterparts for these activities, ranging from Dutch ministries and provincial authorities to EU regulators and U.S. policymakers. Finally, OCI NV is clear about the concrete outcomes it pursues: it has "successfully advocated for the inclusion of mass balance for sustainable production sharing facilities with conventional production," seeks to "ensure that all industrial sectors have a fair share of allowances reflecting the industrial reality," and aims "to accelerate the reduction of industrial CO2 emissions from our Dutch operations and discuss tailored government support such as on regulatory hurdles and funding gaps." This level of detail—covering the specific policies, the mechanisms and targets of engagement, and the precise changes sought—demonstrates comprehensive transparency in the company’s climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	OCI NV states that it "engage[s] with stakeholders on a regular basis through … governmental or regulatory interactions" and confirms "Yes" when asked whether it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," signalling an intention to align its advocacy with climate objectives. It further notes that "our Executive Directors engage with key stakeholders on ESG and sustainability topics," showing that senior leadership participates in external engagement. Nevertheless, the disclosure provides no detail on how lobbying activities are monitored or reviewed, does not identify a committee or individual with formal oversight, and offers no description of processes to assess or correct misalignment in either direct lobbying or trade-association memberships. As such, the evidence shows only a high-level commitment without a transparent governance framework to ensure implementation.	1