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| Overall Assessment |
Analysis |
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Limited
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KGHM Polska Miedź S.A. has established basic oversight of its lobbying activities but does not disclose any climate-specific governance processes. “Lobbying activities in KGHM Polska Miedź S.A. are supervised by the Vice President of the Management Board (Corporate Affairs) and the Executive Director for Legal Affairs,” indicating clear assignment of responsibility for lobbying. The company has implemented “internal regulations … for coordinating the membership of KGHM Polska Miedź S.A. in national and international economic and sector organisations and establishing the principles for participation of KGHM representatives,” and introduced the “Map of External Regulations (MER), which provides a structured database of information on draft legislation” feeding into its compliance management process. However, we found no evidence of any process to align either direct or indirect lobbying with its climate policy, no description of a review or monitoring mechanism specific to climate-related lobbying, and no indication of any board-level or formal body oversight focused on climate-lobbying alignment, which suggests limited governance in this area.
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D
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| Overall Assessment |
Analysis |
Score |
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Limited
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KGHM Polska Miedź S.A. offers only limited insight into its climate-related lobbying. The company refers broadly to working on “climate policy and related taxonomy,” to “amendment of the legal definition of direct lines” and to “streamlining regulations for the functioning of Closed Distribution Systems,” but it does not clearly identify any specific piece of legislation or regulation it has sought to influence. Its descriptions of engagement remain high-level: it cites participation in initiatives such as the Horizon 2020 Framework Programme, cooperation with the Ministry of the Environment, and a role in European sectoral organisations, yet it provides no detail on concrete lobbying mechanisms—no records of meetings, letters, submissions, or the policymaking bodies it approached—so the methods and targets of influence remain opaque. Likewise, the company states general aspirations such as “minimising bureaucratic obstacles,” “reinstituting support for high efficiency cogeneration systems,” and “setting the highest environmental standards,” but it stops short of articulating the specific policy outcomes or legislative amendments it is advocating. As a result, while KGHM acknowledges some engagement with climate-related policy themes, the absence of precise policy references, clear lobbying channels, and defined objectives means its transparency around climate lobbying is minimal.
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D
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