Elisa Oyj

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Elisa Oyj gives a moderate level of transparency on its climate-related lobbying. It names two identifiable policy processes it has engaged with: the Finnish electricity tax reform that extended the lower excise duty (tax category II) to smaller heat-recovering data centres, and the Finnish Government’s consultation on the forthcoming EU Energy Efficiency Directive revision. The company also outlines how it seeks to influence these measures, explaining that it participates in government working groups, provides expert guidance and takes part in formal consultation rounds, and it identifies the Ministry of Transport and Communications, the Finnish Government and the European Commission as its targets. On outcomes, Elisa specifies that it supports including data centres under 0.5 MW in the lower electricity tax band to encourage energy-efficient heat recovery, and explains the rationale for that position, but it does not set out similarly concrete objectives for its engagement on the Energy Efficiency Directive or other issues. Overall, the disclosure provides clear examples of policies and mechanisms but only a single explicit policy outcome, leaving some gaps in the detail of the company’s broader lobbying objectives.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Elisa demonstrates a moderate structure for aligning its climate-related engagement, publicly confirming a position to conduct activities “in line with the goals of the Paris Agreement” and involving its sustainability team in all external communications and advisory processes. For example, “Elisa’s sustainability team has in daily operations for many years worked very closely with the investor relations communications team,” ensuring that “all press releases related to sustainability and climate action are done under this collaboration” and that the team is “usually included also in other forms of external engagement activities, at least in an advisory role.” The company’s CEO even co-signed a COP26 letter urging governments to back net zero targets with robust carbon pricing instruments. However, the company does not disclose a formal policy or review mechanism for climate lobbying alignment, provides no detail on governance of direct or indirect lobbying through trade associations, and does not identify any specific individual or governance body responsible for overseeing its lobbying processes.	2