AP Moller - Maersk A/S

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	A.P. Moller - Maersk A/S has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company explicitly names specific climate policies it has engaged with, such as the EU Emissions Trading System (ETS), the FuelEU Maritime Regulation, the Renewable Energy Directive (RED), and the International Maritime Organization (IMO) GHG Strategy. It provides detailed insights into these policies, including their mechanisms, implications, and legislative processes. For example, Maersk has advocated for the inclusion of lifecycle assessments in the EU ETS and supported the FuelEU Maritime proposal to catalyze the adoption of green shipping fuels. The company also provides clear details about its lobbying mechanisms and targets. It mentions direct engagement with policymakers through bilateral meetings, participation in public fora, and collaboration with trade associations like the World Shipping Council and the Getting to Zero Coalition. Specific targets, such as the IMO, EU regulators, and national authorities, are identified, and the company outlines its participation in global events like COP29 and New York Climate Week. These disclosures reflect a high degree of transparency in both the mechanisms and the policymaking entities targeted. Furthermore, Maersk has been explicit about the outcomes it seeks through its lobbying efforts. It advocates for ambitious measures, such as a global GHG pricing mechanism, a global fuel standard, and the inclusion of all relevant greenhouse gases in the EU ETS. The company also calls for the adoption of a net-zero emissions target by 2050, the phasing out of fossil-fueled vessels, and the establishment of green corridors. These desired outcomes are clearly articulated and tied to specific regulatory changes, demonstrating a strong commitment to advancing decarbonization in the shipping industry. Overall, Maersk's disclosures provide a comprehensive view of its climate lobbying activities and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Maersk exhibits a robust governance approach for climate lobbying alignment, underpinned by clearly articulated oversight and ongoing monitoring of its direct and indirect lobbying activities. The organization underscores its commitment by stating that it is "committed to ensuring that all lobbying activities are conducted in accordance with our commitment to responsible business practices and with the planet and its inhabitants in mind," which dovetails with its broader climate strategy. Moreover, Maersk reinforces this alignment by reviewing its trade association memberships on an annual basis; as articulated in its disclosure, "We review our membership status once a year to ensure that our own policy engagement, as well as the trade associations in which we are members lobby in alignment with the goals of the Paris Agreement." This process is supervised by top-level executives, including CEO Vincent Clerc, who actively participate in global climate initiatives, ensuring that both direct lobbying and the positions taken by affiliated trade associations remain consistent with the company's climate objectives. While some disclosures offered limited details, the comprehensive evidence that highlights clear mechanisms for oversight and accountability indicates strong governance in aligning lobbying activities with climate goals.	3