Turk Hava Yollari AO

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Turkish Airlines has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names specific climate-related policies it has engaged with, such as the "Regulation on the Monitoring of GHG Emissions Originating from Aviation Activities" published on 22/03/2022 and the draft regulation on Sustainable Aviation Fuel (SAF) blending mandates introduced by the Directorate General of Civil Aviation (DGCA) of Türkiye. It also discloses its compliance with international frameworks like the EU ETS, UK ETS, and CORSIA, providing detailed information about its engagement and feedback processes. Turkish Airlines has been clear about its lobbying mechanisms, including direct engagement with policymakers such as the Turkish DGCA through official letters, stakeholder meetings, and workshops, as well as indirect lobbying through trade associations like the International Air Transport Association (IATA) and Airlines International Representation in Europe (AIRE). The company further enhances transparency by being registered on the EU Transparency Register and actively participating in industry committees to influence climate strategies. Regarding outcomes sought, Turkish Airlines has disclosed specific goals, such as aligning with SAF blending mandates to achieve carbon neutrality by 2050, advocating for long-term purchase agreements with SAF suppliers, and supporting the development of fuel-efficient technologies and operational optimizations. These efforts are aimed at reducing greenhouse gas emissions and meeting global climate targets, including the Paris Agreement's 1.5°C goal. The company also seeks to improve systems like the Data Management System (DMS) for monitoring and verifying GHG emissions, demonstrating its commitment to achieving measurable environmental outcomes and aligning with international best practices.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Turkish Airlines demonstrates a strong governance process for climate lobbying alignment, particularly through its Sustainability Committee, which is chaired by the CEO and convenes quarterly. The committee is responsible for aligning climate-related strategies and goals with the company's sustainability policy and monitoring progress. The CEO, as a member of the Board of Directors, oversees these activities, ensuring alignment with the company's climate transition plan and broader sustainability objectives. The company explicitly mentions its engagement in direct and indirect lobbying activities, including through trade associations such as the International Air Transport Association (IATA) and Airlines International Representation in Europe (AIRE). Turkish Airlines aligns its lobbying efforts with global environmental treaties, including the Paris Agreement, and evaluates its engagement to ensure consistency with these commitments. For example, the company states, "Recognizing Türkiye's ratification of the Paris Agreement in 2021 and its commitment to achieving net-zero carbon emissions by 2053, we align our business strategies accordingly." Additionally, Turkish Airlines has a public commitment to conduct its engagement activities in line with global environmental treaties and policy goals, as evidenced by its registration on the EU Transparency Register. However, while the governance structure and processes are robust, there is no mention of a detailed lobbying audit or comprehensive review of alignment across trade associations, which would elevate the governance process further.	3