Shell PLC

Our advocacy, directly with governments, and indirectly through industry associations and coalitions, is a key part of how we implement our strategy. Shell engages with governments, regulators and policymakers in different ways to help shape policy, legislation and regulation. [...] We believe that lobbying transparency is important. We engage with investors, international and civil society organisations, companies and industry associations as we further develop our approach to lobbying transparency. Initiatives such as the Global Standard on Responsible Corporate Climate Lobbying and the Climate Action 100+ Net Zero Company Benchmark aim to encourage greater transparency around climate-related lobbying by companies and industry associations. [...] We have updated our principles for participation in industry associations. These principles set out our governance of our memberships. They describe how we review the climate and energy transition policy and advocacy positions of key associations, and how we address misalignment. In line with our principles, we publish a review of the policy and advocacy positions of our key industry associations every two years. Where we identify misalignment with our positions, we set out how we plan to address this and provide an update the following year. [...] Over the coming year, we intend to publish information about our direct and indirect climate and energy transition lobbying in some additional countries that are significant for our strategy. This includes: * Adding information about our lobbying in these additional countries to our website; * Expanding the scope of our list of industry associations and similar organisations to cover these countries; and * Expanding the scope of our Climate and Energy Transition Lobbying Report to cover these countries. This includes providing information about our direct advocacy and reviews of some additional industry associations.

We will remain a member of APPEA at the current time. We will continue to track alignment between APPEA's climate and energy transition-related positions and our own, and will be transparent about where we find differences. We will continue to engage the association, including through our positions on APPEA's board and committees, in areas where we have different views.

**Political engagement**

Shell engages with governments, regulators and policymakers to help shape comprehensive policy, legislation and regulation. We advocate our positions on matters which affect us, our employees, customers, shareholders or local communities, in accordance with our values and the [Shell General Business Principles.](https://www.shell.com/about-us/our-values.html)

In the European Union (EU) and the USA, we report expenditure associated with our lobbying activities, which includes estimated percentages of industry association costs, in line with the requirements and guidelines set out in the EU Transparency Register and the US Lobbying Disclosure Act respectively. There are different rules for which costs should be reported in these two submissions and we are required to comply with the appropriate requirements for each jurisdiction. These submissions are publicly available:

In the EU, Shell's reported estimated annual costs related to activities covered by the register were €5,500,000 to €5,999,999 in 2022.
In the USA, Shell's reported expenses related to lobbying practices were $6,660,000 in 2022.

In 2022, we continued to advocate our policy positions on climate and the energy transition and provided updates about our advocacy on our website. For example, we supported a range of policy measures within the EU's Fit for 55 package, and supported the US Inflation Reduction Act that contains various clean energy provisions. As well as many other events, we attended the UN Climate Change Conference (COP27) and UN Biodiversity Conference (COP15) as observers, to listen and learn.

Our Climate and Energy Transition Lobbying Report provides an overview of our lobbying in 2022 and that of some of our key industry [associations. Read the report and further information about our advocacy and political engagement approach at www.shell.com/advocacy.](http://www.shell.com/advocacy)

Shell benefits from its membership of the Hydrogen Council, particularly in relation to its work and engagement to enable hydrogen and hydrogen policy. It also publishes hydrogen-related studies and provides a platform for government and companies to connect on hydrogen issues. [...] We will remain a member of the Hydrogen Council. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between the Hydrogen Council's climate and energy transition-related positions and our own.

We aim to be at the forefront of the drive for greater transparency around climate and energy-transition-related policy engagement. We set out our approach, policy and advocacy positions, and information about our industry association memberships, on our website. In March 2023, we plan to publish our first Climate and Energy Transition Lobbying Report. This report reviews our lobbying in 2022 and our memberships of industry associations. We continue to work to ensure our memberships of industry associations support our climate and energy transition policy positions.

Shell benefits from its membership of IGU, in particular from IGU's advocacy of the benefits of gas and its role in the energy transition. IGU also participates in international forums, such as the UNFCCC Conference of the Parties.

We have found IGU to have some misalignment with our climate and energy transition-related policy positions.

We will urge IGU to:

* Support reducing methane emissions throughout the natural gas supply chain through direct regulations such as performance standards based on robust monitoring, reporting and verification frameworks. Explicitly state support for ending routine flaring by 2030 or sooner to help achieve such standards.

We will encourage IGU to:

* Explicitly state support for net-zero emissions by 2050.
* Support policies to facilitate the decarbonisation of heavy industry, including those that create demand and encourage supply of low-carbon energy in industry.
* Support improving energy efficiency through standards and regulatory instruments covering key sectors of the economy.

We will remain a member of IGU at the current time. We will continue to track alignment between IGU's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views.

Shell benefits from its membership of VNO-NCW, which is an influential voice in the national policy debate on the competitiveness of Dutch industry. Participation provides a platform for us to engage with other companies on issues such as climate change, pension reform, gender equality and social licence to operate. [...] We will remain a member of VNO-NCW. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between VNO-NCW's climate and energy transition-related positions and our own.

We will remain a member of API at the current time. We will continue to track alignment between API's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views, including through our positions on API's climate committee, board and executive committee.

We will remain a member of QRC at the current time. We will continue to track alignment between QRC's climate and energy transition-related positions and our own, and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views.

We will remain a member of AIGN. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between AIGN's climate and energy transition-related positions and our own.

Shell benefits from its membership of WBCSD, which provides an important platform for Shell to exchange information with businesses around the world on issues relating to sustainability. WBCSD also brings the voice of business to the UN climate and biodiversity negotiations and will serve as the secretariat for the Energy Transition Alliance at COP28. [...] We will remain a member of WBCSD. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between WBCSD's climate and energy transition-related positions and our own.

## CLIMATE POLICY ENGAGEMENT

###### Robust and sustainable government policies GREATER TRANSPARENCY will be critical to help the world achieve the We aim to be at the forefront of the drive for greater transparency around

political engagement. We set out our approach, including our principles

###### goal of the Paris Agreement and net-zero for responsible lobbying, in our statement on corporate political emissions by 2050. These must include engagement which is published on our website [N]. policies that accelerate the move to low- Our principles for participation in industry associations govern how we carbon energy in industries that are hard manage our relationships with industry associations on climate-related

policy. They build on the Shell General Business Principles and the Shell

###### to decarbonise, sector by sector. Code of Conduct, and have been incorporated in the Shell Control

Framework, which sets the requirements for how all Shell entities operate.

Shell's Powering Progress strategy includes working with governments The principles aim to ensure our memberships of industry associations do
to support the policies and regulatory frameworks to accelerate not undermine our support for the Paris Agreement and that they support
the transition to net zero. the development of government policies that could help the world achieve

net-zero emissions by 2050.

We are seeing a growing number of countries aiming for net-zero emissions
and enhancing their nationally determined contributions (NDCs). The USA In 2019, we published our first Industry Associations Climate Review,
has recently rejoined the Paris Agreement, for example, China has set out and were one of the first companies to report this information [O].
its plans to reach net zero by 2060, and the European Union (EU) has The review assessed our climate-related policy alignment with
committed to climate neutrality, or net-zero emissions, in 2050. 19 industry associations against our 2019 climate-related policy

positions. The following year we published an update to our review.

**ENGAGING WITH GOVERNMENTS**
Our expertise in providing energy can help to shape effective policy, In 2020, we updated Shell's climate-related policy positions and
legislation and regulation, and we engage with governments, regulators published them on our website [P]. These positions include support for
and policymakers directly and indirectly, including through industry the goal of the Paris Agreement and for the development of policies to
associations. We are also working with other companies, governments help the world to achieve net-zero emissions by 2050. They also include
and investors through coalitions to identify the policies needed in sectors support for carbon pricing, carbon capture utilisation and storage
such as aviation, shipping and road freight to help change demand and nature-based offsets.
and enable faster decarbonisation.

In the newly published 2021 Industry Associations Climate Review,

We are members of the Mission Possible Partnership sectoral coalitions we have reviewed 36 associations. We plan to publish our next
for aviation, shipping, road freight and steel. Each of these coalitions update in 2022.
works to help accelerate decarbonisation pathways, including through
policy engagement. For example, we are a member of the Clean Skies We will continue to work with governments, other companies, investors,
for Tomorrow initiative, which has developed a joint policy proposal non-governmental organisations, coalitions and industry associations
for a sustainable aviation fuel mandate in the EU which would require to help society achieve the goal of the Paris Agreement and net-zero
airlines to use an increasing ratio of sustainable aviation fuel. emissions. We will also continue to work towards greater transparency

around climate lobbying and reporting.

Shell is also a member of the Jet Zero Council (JZC) in the UK, a partnership
between industry and government. JZC aims to deliver zero-emission
transatlantic flight within a generation, and to drive new technologies
and innovative ways to cut aviation emissions. Shell is also a member of
the European Round Table for Industry (ERT) which has called on the EU
institutions to introduce sectoral roadmaps to net-zero emissions [M].

[M] https://ert.eu/wp-content/uploads/2021/02/2021-02-25-Statement-on-Sectoral-Approaches.pdf

[N] www.shell.com/advocacy

Shell is a member of the UKPIA Council which governs UKPIA.[2] [...] We will remain a member of UKPIA. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between UKPIA's climate and energy transition-related positions and our own.

Shell benefits from its membership of VEMOBIN, especially in relation to industry and transport public policy. [...] We have found VEMOBIN to be aligned with our climate and energy transition-related policy positions. [...] We will remain a member of VEMOBIN. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between VEMOBIN's climate and energy transition-related positions and our own.

We will remain a member of ACP. We will continue to engage the association on climate and energy transition-related topics. We will continue to track alignment between ACP's climate and energy transition-related positions and our own.

Shell benefits from its membership of CFA, in particular through CFA's advocacy of policies that shape the downstream business. [...] We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between CFA's climate and energy transition-related positions and our own.

Shell benefits from its membership of CAPP, especially through CAPP's role as a platform for presenting a unified voice to government and the public on upstream policies and topics, such as climate, carbon leakage, health and safety, and engagement with Indigenous Peoples and other stakeholders. [...] We will remain a member of CAPP at the current time. We will continue to track alignment between CAPP's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views, including through our involvement in CAPP's climate policy committees and board.

Shell benefits from its membership of ACC, particularly in relation to its federal- and state-level advocacy on topics such as chemical management, product stewardship, trade policy, transport and infrastructure. [...] We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between ACC's climate and energy transition-related positions and our own.

This is Shell's first Climate and Energy Transition Lobbying Report, which gives details of our lobbying in 2022 and includes our review of industry associations. [...] This is the fifth year that we have reviewed our memberships of industry associations to assess whether they are consistent with our views on climate action. Our reviews have led to constructive engagements with our industry associations, and we have seen positive results from these engagements in recent years. In the USA, for example, we have seen some associations change their positions to support carbon pricing and the direct regulation of methane emissions. [...] This year, we have reviewed 39 associations. I am encouraged to see that around three-quarters are aligned with our global climate and energy transition-related policy positions. While we have seen some change in the remaining associations, we want to see more – and at a faster pace. In this report, we give information about where we have different positions to our industry associations. In some cases, we have lobbied governments directly and through coalitions to support our positions. [...] I am writing to the 10 industry associations where we have found some misalignment to call for changes to some of their positions. For example, we would like some associations to step up their advocacy in support of net zero by 2050 and reductions in methane emissions. We look forward to engaging with them in the months ahead.

The Safety, Environment and Sustainability Committee (SESCo) is one of four standing committees of the Board of Directors of Shell plc. The overall role of SESCo is to assist the Board in reviewing the policies, practices, targets and performance of Shell, primarily with respect to safety, environment including climate change, and broader sustainability. [...] The Committee also reviewed wider matters of public concern such as plastic waste, methane emissions, the flaring of natural gas, water scarcity, just transition, human rights, diversity and inclusion, and access to energy in low- and middle-income countries. [...] SESCo continued to monitor Shell's approach to the health of its employees and contractors, in terms of mental well-being in particular. The Committee also continued to review the security risks faced by Shell and how these risks are being proactively managed. [...] Shell engages with governments, regulators and policymakers to help shape comprehensive policy, legislation and regulation. We advocate our positions on matters which affect us, our employees, customers, shareholders or local communities, in accordance with our values and the Shell General Business Principles. [...] In the European Union (EU) and the USA, we report expenditure associated with our lobbying activities, which includes estimated percentages of industry association costs, in line with the requirements and guidelines set out in the EU Transparency Register and the US Lobbying Disclosure Act respectively. There are different rules for which costs should be reported in these two submissions and we are required to comply with the appropriate requirements for each jurisdiction. These submissions are publicly available: In the EU, Shell's reported estimated annual costs related to activities covered by the register were €5,500,000 to €5,999,999 in 2022. In the USA, Shell's reported expenses related to lobbying practices were $6,660,000 in 2022. [...] Our Climate and Energy Transition Lobbying Report provides an overview of our lobbying in 2022 and that of some of our key industry associations. Read the report and further information about our advocacy and political engagement approach at www.shell.com/advocacy.

Shell benefits from being a partner company of BusinessEurope, in particular through the association's role in the EU policy debate on the global competitiveness of European industry. Our participation provides us with a platform to interact with representatives of national business associations. [...] We will remain a member of BusinessEurope. We will continue to track alignment between BusinessEurope's climate and energy transition-related policy positions and our own.

Shell benefits from its membership of CME, including its advocacy on issues relating to environment, climate, economic competitiveness, skills development, health and safety, infrastructure and land access. [...] We will remain a member of CME at the current time. We will continue to track alignment between CME's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views.

We will remain a member of Hydrogen Europe. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between Hydrogen Europe's climate and energy transition-related positions and our own.

We will remain a member of Ipieca. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between Ipieca's climate and energy transition-related positions and our own.

We will remain a member of ERT. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between ERT's climate and energy transition-related positions and our own.

We will remain a member of NGSA. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between NGSA's climate and energy transition-related positions and our own.

We have found OGCI to be aligned with our climate and energy transition-related policy positions. We will remain a member of OGCI. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between OGCI's climate and energy transition-related positions and our own.

The Safety, Environment and Sustainability Committee (SESCo) assists the Board of Directors of Shell plc (the "Board") in reviewing the practices and performance of the Shell Group of Companies (the "Group"), primarily with respect to Safety, Environment including Climate Change, and Sustainability. The Committee oversees the non-financial elements of Shell's Powering Progress strategy. (www.shell.com/investors/environmental-social-and-governance/board-of-directors) (AR, p163) Safety, Environment and Sustainability Committee (SESCo): The SESCo focused on Shell's safety and environmental performance and assurance programme in 2022, as well as targets for the energy transition and sustainability elements of Shell's Powering Progress strategy. [...] Shell senior executives approve our advocacy priorities each year. (C&ET Lobbying Report 2022) Our global climate and energy transition policy positions serve as a global framework for Shell's advocacy with governments, international organisations, industry associations, coalitions and other stakeholders globally, regionally and within countries. These positions are in line with Powering Progress, our strategy to accelerate the transition of our business to net-zero emissions. By advocating these positions as we transform our business, we believe we are supporting the energy transition and the Paris Agreement. We prioritise and adapt these positions at an international and country level, ensuring we support our Powering Progress strategy while taking account of the local political and policy landscape. Our global climate and energy transition policy positions also served as the basis of our review of industry associations. Our Climate and Energy Transition Lobbying Report 2022 provides further details of our policy and advocacy internal governance.

We will remain a member of AEC. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between AEC's climate and energy transition-related positions and our own.

We will remain a member of SEIA. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between SEIA's climate and energy transition-related positions and our own.

We will remain a member of OEUK. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between OEUK's climate and energy transition-related positions and our own.

We will remain a member of EPSA. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between EPSA's climate and energy transition-related positions and our own.

We will remain a member of WSPA at the current time. We will continue to track alignment between WSPA's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views, including through our positions on WSPA's climate committee, government affairs committee and board of directors.

We have conducted a more detailed review of our membership of TXOGA, and have decided to remain in the association at the current time. We believe that its positions are changing, and that we can have more impact within the association than outside of it. We also recognise the value that TXOGA brings to us in relation to its advocacy on CCUS and hydrogen. Supportive CCUS and hydrogen regulations are crucial enablers for our business strategy in the region to develop industrial decarbonisation hubs. TXOGA has been advancing CCUS with the Texas state government during 2022, resulting in the association authoring a draft CCUS bill for the 2023 Texas State Legislative Session. TXOGA has also provided input into additional bills being drafted in support of hydrogen production projects within the state and associated pipelines for distribution of hydrogen across the state once projects become operational. [...] We will keep our membership of TXOGA under review during the next 12 months. We will use this period to continue to engage TXOGA, including through our position on TXOGA's board and our membership of its work groups on carbon management and climate policy. [...] We will continue to track alignment between TXOGA's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views. We will provide an update in our next report.

In the European Union (EU) and the USA, we report expenditure associated with our lobbying activities, which includes estimated percentages of industry association costs, in line with the requirements and guidelines set out in the EU Transparency Register and the US Lobbying Disclosure Act respectively. There are different rules for which costs should be reported in these two submissions and we are required to comply with the appropriate requirements for each jurisdiction. These submissions are publicly available: [...] Our Climate and Energy Transition Lobbying Report provides an overview of our lobbying in 2022 and that of some of our key industry associations. Read the report and further information about our advocacy and political engagement approach at www.shell.com/advocacy.

Shell benefits from its strategic partnership with IATA, as the relationship allows us to connect with other companies and organisations in the aviation industry. Participation in IATA's technical fuels forum allows us to engage on issues such as fuel management, compliance standards, and health, safety, security and the environment. We also benefit from IATA's alternative fuels symposium. [...] We will remain a member of IATA. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between IATA's climate and energy transition-related positions and our own.

Shell benefits from its membership of Eurogas, in particular from its policy advocacy supporting the role of renewable and low-carbon gases in the transition to climate neutrality. [...] We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between Eurogas's climate and energy transition-related positions and our own.

Shell benefits from its membership of NAM, in particular from its expertise in trade, environmental regulation, the role of natural gas and tax. [...] We will remain a member of NAM at the current time. We will continue to track alignment between NAM's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views, including through our position on NAM's board.

Shell benefits from its membership of Cefic, in particular through the association's advocacy related to issues that impact the chemical sector. These include regulations related to emissions (air, water and waste) and to chemical health and safety, energy and climate. [...] We will remain a member of Cefic. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between Cefic's climate and energy transition-related positions and our own.

We will remain a member of IETA. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between IETA's climate and energy transition-related positions and our own.

Shell benefits from its membership of IOGP, in particular through the association's engagement with regulators in many jurisdictions. We value the forum that IOGP presents to share knowledge and good practices with industry peers, and to achieve improvements in areas such as safety, the environment, security and social responsibility. [...] We will remain a member of IOGP. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between IOGP's climate and energy transition-related positions and our own.

We will remain a member of BCA. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between BCA's climate and energy transition-related positions and our own.

Shell is a member of the CBI President's Committee, which acts as an advisory body to the CBI president and CBI executive. [...] We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between CBI's climate and energy transition-related positions and our own.

Shell benefits from FuelsEurope's advocacy on issues that impact the refining sector. This includes energy and climate regulations, transport fuels and emissions to air, water and waste. Both FuelsEurope and Concawe provide best practice on managing risks to the environment from the production and use of oil products.

We found FuelsEurope to be aligned with our climate and energy transition-related policy positions.

We will remain a member of FuelsEurope. We will continue to engage the association on climate and energy transition topics. We will continue to track alignment between FuelsEurope's climate and energy transition-related positions and our own.

Shell benefits from its membership of USCC, especially on broader policy issues that affect Shell as a major contributor to the US economy such as energy policy, tax reform, international trade and investment, and innovation. [...] We will remain a member of USCC at the current time. We will continue to track alignment between USCC's climate and energy transition-related positions and our own and will be transparent about where we find differences. We will continue to engage the association in areas where we have different views, including through our positions on USCC's board and task force on climate actions.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]We provide our Corporate Political Engagement Statement at www.shell.com/advocacy. This includes our principles for responsible lobbying that apply to all staff.
We advocate on public policy issues in line with the Shell General Business Principles and based on our advocacy priorities, which are aligned with our business strategy across lines of business and geographies. Shell senior executives approve our advocacy priorities each year.
Our global climate and energy transition policy positions serve as a general global framework for our advocacy with governments, international organisations, industry associations, coalitions and other stakeholders globally, regionally and within countries. These positions are in line with Powering Progress, our strategy to accelerate the transition of our business to net-zero emissions. By advocating these positions as we transform our business, we believe we are supporting the energy transition and the Paris Agreement. We provide examples of our advocacy at www.shell.com/advocacy.
Please note that information provided in this section is not an exhaustive list of Shell's engagements with policy makers nor the trade associations. We may be engaging with policy makers also on policies, laws or regulations not listed in this section and we may be members of some other associations on CDP's drop-down list, but since they are not included in our 2021 Industry Associations Climate Review these have not been included.
Our Industry Association Climate Reviews (www.shell.com/industryassociations) assess alignment between the positions that key industry associations support and those that we support. Our latest detailed review in 2021 featured 36 key associations; we found "material misalignment† with one association, "some misalignment† with seven, and "alignment† with 28.
Information provided in C12.3b relates to 22 of these associations; these have been listed because they appear on the CDP drop-down list in C12.3b, or because we paid the association $500,000 or more in 2021, or we found "some misalignment† or "material misalignment† in our 2021 review.
Our 2021 review used our 2020 climate-related policy positions as a review basis.
In 2022, we published an Industry Associations Climate Review Update. This is a progress update about associations where we identified misalignment in the 2021 review; we set out the actions taken by Shell, key changes in the associations' positions and next steps. An update is planned for 2023.