Orsted AS

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Ørsted provides highly detailed and specific disclosure of its climate-policy lobbying. It names multiple individual measures it works on, including the EU “Carbon Border Adjustment Mechanism”, a “CO2 tax on heating” in Denmark, discussions on a UK “carbon floor”, the “EU ETS”, and “electricity market rules … for the integration of renewable electricity” in Asia-Pacific, as well as broader frameworks for offshore wind and energy-efficiency policy, each linked to the relevant jurisdiction. The company also explains how it tries to influence these measures, citing “direct dialogue with the political level, government officials, and other relevant stakeholders”, “regular interactions with Commission officials”, “regular exchanges with Members of the European Parliament”, and “dialogue with national policy makers in EU on Carbon Border Adjustment Tax (CBAM), Denmark (CO2 tax on heating), and stakeholders in the UK on carbon floor”, thereby revealing both the mechanisms used and the specific targets it contacts across Denmark, the UK, Germany, the Netherlands, Taiwan, the US and EU institutions. Finally, Ørsted is explicit about what it wants to achieve: it “supports any pricing of CO2”, backs initiatives to “stabilize and strengthen the price signal from the EU ETS”, advocates a “stable and transparent regulatory framework for renewable energy in general and offshore wind in particular”, and endorses electricity-market designs that enable renewables. By clearly describing the policies, the channels and audiences for engagement, and the concrete outcomes it seeks, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Ørsted has implemented a structured governance framework for its political and regulatory engagement to align activities with its climate strategy, anchoring all efforts in the Paris Agreement goals and overseen by designated corporate functions. The company states it will "conduct all our political and regulatory engagement activities in line with the goals of the Paris Agreement," with "Group Regulatory Affairs coordinates the individual business units' local interests and ensures that positions and messages are consistent across markets and across business units" and working closely with the "Corporate Strategy department who acts as an advisory body to the CEO." Country specialists "keep track of new legal initiatives and changes to regulation within our footprint" to inform direct lobbying. However, Ørsted does not disclose a formal process for reviewing or aligning its indirect lobbying through industry associations against its climate policy, nor does it publish an independent audit or detailed report of its lobbying activities to demonstrate ongoing oversight and accountability.	2