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| Overall Assessment |
Comment |
Score |
| Strong |
Salzgitter AG provides a high level of detail about its climate-policy engagement. It identifies several concrete legislative files it works on, including the European Emissions Trading System, forthcoming amendments to emissions trading from 2021, the EU “Fit for 55” package, the European Green Deal and the German Federal Government’s “Action Plan for Steel – For a strong Steel Industry in Germany and Europe.” The company also explains the channels it uses to influence these measures: it collaborates on position papers through the European and German steel associations and other energy-intensive industry bodies, maintains a liaison office in Brussels, is registered in the EU Transparency Register, and holds direct dialogue with decision-makers in communal, regional, national and European bodies as well as participating in government commissions and advisory groups. Finally, Salzgitter AG is explicit about what it wants to achieve, advocating for the full internalisation of CO₂ costs while preserving robust carbon-leakage protection, the allocation of EU-ETS certificates for new low-carbon steel technologies on terms equivalent to the conventional blast-furnace route, and improvements to “Fit for 55” and the Carbon Border Adjustment Mechanism to safeguard industry competitiveness. Together, these disclosures give a clear picture of what the company lobbies for, how it does so and the policy outcomes it seeks.
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3
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| Overall Assessment |
Comment |
Score |
| Limited |
Salzgitter AG provides some insights into its lobbying activities, particularly its engagement with political institutions and associations, but the disclosures lack a clear governance framework specifically addressing climate lobbying alignment. The company states that it "follows the political debate systematically, maintain[s] contact with relevant political institutions and contribute[s] our expertise to political processes," and highlights its participation in various associations such as the European Steel Association Eurofer and the German Hydrogen and Fuel-Cell Association. However, while it mentions its involvement in climate-related policy areas like "EU emissions trading" and "low carbon technologies," there is no explicit description of a governance process to ensure that these lobbying activities align with its climate commitments. The evidence does not disclose any specific individual or committee responsible for overseeing lobbying alignment, nor does it describe mechanisms such as periodic reviews, monitoring processes, or criteria for assessing alignment with climate goals. Additionally, while the company emphasizes transparency through its registration in the EU’s Transparency Register and the national transparency register, this does not constitute a governance process for lobbying alignment. Overall, the company mentions its lobbying activities and climate-related focus areas but does not provide evidence of a structured governance process to ensure alignment with its climate commitments.
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1
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