Direct Lobbying Transparency
| Overall Assessment | Comment | Score |
|---|---|---|
| Comprehensive | ORLEN SA provides extensive and specific disclosure of its climate-related lobbying. It names a wide range of concrete policies it engages on, including the Draft Delegated Act on low-carbon fuels that supplements Directive (EU) 2024/1788, the Industrial Emissions Directive, the EU Methane Regulation, the Directive on common rules for the internal markets in renewable and natural gases and hydrogen, the EU ETS fourth-phase legislation, CBAM, RED, EED, AFIR, EPBD and the Clean Industrial Deal State Aid Framework, demonstrating full transparency on what it is lobbying. The company also explains how and where it lobbies: it “responded to the public consultation launched by the European Commission,” “actively participates in legislative processes,” collaborates with Poland’s Ministry of Climate and Environment and other ministries, and channels positions through industry bodies such as CO2 Value Europe, Hydrogen Europe, FuelsEurope, CEFIC and IOGP, thereby revealing multiple direct and indirect mechanisms and identifying targets such as the European Commission, EU institutions and Polish government departments. Finally, ORLEN sets out the concrete outcomes it seeks, for example advocating a “technology-neutral approach” in the low-carbon fuels delegated act, opposing the inclusion of oil and gas in the IED, supporting “sustainable and cost-effective reduction of methane emissions,” calling for state aid that is “based on technological neutrality,” and backing specific Fit-for-55 goals such as expanding the EU ETS and introducing CBAM. This level of detail across policies, mechanisms and desired legislative changes demonstrates a comprehensive degree of transparency in the company’s climate-policy lobbying. | 4 |