Fortum Oyj – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Fortum discloses a well-structured climate-lobbying governance framework that covers both its own advocacy and the activities of the associations it belongs to, supported by a recurring public review. The company states that it "has a governance model in place for its public affairs activities that defines objectives, scope, roles and responsibilities as well as the governing framework of Public Affairs within Fortum", and that "Fortum Public Affairs leads the process relating to preparation, coordination and adoption of Fortums Group level lobbying positions", identifying a dedicated internal body with responsibility for oversight and alignment. Its policy explicitly links lobbying to climate strategy by requiring that "Fortums lobbying messages and activities shall also be consistent with the Paris Agreement. The aim is that this also applies to the key industry associations with whom Fortum cooperates", showing coverage of both direct and indirect lobbying. To verify and enforce that alignment, Fortum confirms that it "compiles annually, starting in 2021 a Climate Lobbying Review which assesses the Paris alignment of the key industry associations with whom Fortum cooperates, as well as the Paris alignment of Fortums own lobbying positions. This report is part of Fortums annual Sustainability Reporting", providing an in-depth, recurring audit that is publicly released. The latest update notes that "Vuoden 2023 lopussa julkaisimme viimeisimmn pivityksen ilmastopoliittiseen edunvalvontaan liittyvi toimia ja kytntj kuvaavaan Climate Lobbying Review -katsaukseemme", confirming ongoing disclosure. Quarterly assessment of lobbying priorities (strategic priorities are yearly translated to concrete lobbying priorities, which are assessed on a quarterly basis) and the deployment of an internal transparency-register tool further illustrate continuous monitoring. While the evidence does not mention board-level sign-off, the clear assignment of responsibility to the Public Affairs function, the annual public Climate Lobbying Review and explicit commitment to Paris-aligned advocacy indicate strong, comprehensive governance of both direct and trade-association lobbying activities. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Fortum discloses a well-structured climate-lobbying governance framework that covers both its own advocacy and the activities of the associations it belongs to, supported by a recurring public review. The company states that it "has a governance model in place for its public affairs activities that defines objectives, scope, roles and responsibilities as well as the governing framework of Public Affairs within Fortum", and that "Fortum Public Affairs leads the process relating to preparation, coordination and adoption of Fortums Group level lobbying positions", identifying a dedicated internal body with responsibility for oversight and alignment. Its policy explicitly links lobbying to climate strategy by requiring that "Fortums lobbying messages and activities shall also be consistent with the Paris Agreement. The aim is that this also applies to the key industry associations with whom Fortum cooperates", showing coverage of both direct and indirect lobbying. To verify and enforce that alignment, Fortum confirms that it "compiles annually, starting in 2021 a Climate Lobbying Review which assesses the Paris alignment of the key industry associations with whom Fortum cooperates, as well as the Paris alignment of Fortums own lobbying positions. This report is part of Fortums annual Sustainability Reporting", providing an in-depth, recurring audit that is publicly released. The latest update notes that "Vuoden 2023 lopussa julkaisimme viimeisimmn pivityksen ilmastopoliittiseen edunvalvontaan liittyvi toimia ja kytntj kuvaavaan Climate Lobbying Review -katsaukseemme", confirming ongoing disclosure. Quarterly assessment of lobbying priorities (strategic priorities are yearly translated to concrete lobbying priorities, which are assessed on a quarterly basis) and the deployment of an internal transparency-register tool further illustrate continuous monitoring. While the evidence does not mention board-level sign-off, the clear assignment of responsibility to the Public Affairs function, the annual public Climate Lobbying Review and explicit commitment to Paris-aligned advocacy indicate strong, comprehensive governance of both direct and trade-association lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Fortum provides a highly detailed picture of its climate-policy engagement. It names multiple identifiable measures it has worked on, including the "revision of the EU Energy Efficiency Directive," reforms to the "EU Emissions Trading System" such as changes to the Market Stability Reserve and Linear Reduction Factor, and support for the EU’s "at least 55 %" 2030 emissions-reduction target and 2050 climate-neutrality goal. The company is equally clear about how and where it lobbies: it undertakes direct dialogue "in close collaboration with the European Commission, Parliament and Council," meets "officials and decision-makers" in member states, and pursues indirect advocacy through the Union of the Electricity Industry – Eurelectric, the UN Global Compact’s Caring for Climate initiative and the World Bank’s Carbon Pricing Leadership Coalition, while also employing external advisers and registering in the EU and Finnish transparency registers. Fortum sets out precise outcomes it wants from this activity—for example, keeping the Energy Efficiency Directive’s objectives intact while adjusting targets to the new 2030 goal, securing a “strong” Market Stability Reserve, expanding carbon pricing to maritime, heating and transport, "streamlining permitting processes for renewable energy investments," creating recycled-content targets, and ensuring "favorable conditions for existing and new nuclear power plants." By articulating concrete legislative objectives, the mechanisms it uses, the bodies it targets and the specific policy instruments involved, Fortum demonstrates comprehensive transparency around its climate-related lobbying.	A