Outokumpu Oyj

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate Outokumpu provides a fair amount of detail on the climate-related policy issues it addresses, naming several concrete measures such as the EU Emissions Trading System, the Carbon Border Adjustment Mechanism (CBAM), the Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive – all referenced as part of the EU “Omnibus Simplification Package” – as well as the idea of EU-level “electrification aid” for energy-intensive industries. By listing more than three identifiable policies, the company demonstrates solid transparency on what it lobbies. The description of how it lobbies, however, is much thinner: the company notes direct discussions with “Mona Neubaur, the Minister for Economic Affairs, Industry, Climate Protection, and Energy of North Rhine-Westphalia,” participation in industry associations such as Eurofer, and appearances at events like Climate Week NYC, but it rarely explains the format of those engagements or identifies further concrete policymaking targets. On desired outcomes, Outokumpu goes beyond broad aspirations by calling for “electrification aid … in accordance with the EU’s recommendations” and for safeguards that “avoid carbon leakage by free allocation in ETS or by effective corresponding rules in the CBAM,” explaining that these changes are needed to preserve competitiveness and enable decarbonisation. These stated objectives give some clarity on the direction of its advocacy, yet most other references remain high-level appeals for “long-term, predictable policies” or “global carbon pricing,” without specific targets or amendments. Taken together, the disclosures offer moderate transparency overall: clear on which policies are in scope and the high-level outcomes sought, but relatively limited about the precise lobbying channels and decision-makers addressed. 2
Lobbying Governance
Overall Assessment Comment Score
Limited Outokumpu outlines its membership in various trade associations, noting that "Outokumpu is a member of international organizations and confederations, including International Chamber of Commerce (ICC), Eurofer, International Chromium Development Association (ICDA), EUROALLIAGES and EUROSLAG," and that it "provides relevant information to decision-makers and experts relating to the development of the business environment and legislation." It also states that it is "actively participating in the position finding process in the associations Committee meetings" and confirms a "public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement." However, the company does not disclose any formal governance process for reviewing or managing lobbying alignment, no named individual or formal body responsible for oversight of its engagement activities, nor any detailed process for monitoring that its direct or indirect lobbying is consistent with its climate change strategy. 1