Stora Enso Oyj

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Stora Enso Oyj has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names several EU-level policies it has engaged with, such as the "Fit for 55 climate package with a focus on Land Use Land Use Change and Forest revision," "Deforestation Regulation," "Nature Restoration Regulation," and "EU Taxonomy." Additionally, it provides further details on its engagement with consultations on Critical Raw Materials, bio-based and compostable plastics, and revisions to directives like the Waste Framework Directive. Stora Enso also discloses its lobbying mechanisms, including direct engagement with the "Commission, European Parliament as well as member states," and describes specific activities such as "providing constructive and detailed evidence" and responding to "EU consultations." These disclosures identify both the mechanisms used and the policymaking entities targeted, ensuring transparency in how the company conducts its lobbying efforts. Furthermore, the company has been transparent about the specific outcomes it seeks through its lobbying efforts, such as advocating for "sustainable forest management" to enhance biodiversity while optimizing carbon storage and opposing the merger of agricultural and forest sectors in the LULUCF policy. It also supported the "Deforestation Regulation" but engaged to achieve "a more workable and therefore more ambitious definition of deforestation in the regulation." These detailed disclosures reflect a high level of transparency in the company's climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Stora Enso has established a defined governance process to ensure alignment of its climate lobbying activities with its overall climate change strategy. The company coordinates all consultation responses, position papers, and engagement issues through its Public Affairs Forum, which includes all Heads of Sustainability from its business divisions as well as Group Sustainability and Group Strategy functions. "Issues of strategic importance, or where there may be differing positions among divisions, are elevated and brought to the Steering Group for decision." The Steering Group, which is the ultimate decision-making body, consists of senior leadership including the President and CEO, Deputy CEO, and other executives responsible for sustainability, legal, and communications. Furthermore, Stora Enso has a robust organizational structure with public affairs teams in key locations such as Helsinki, Stockholm, and Brussels, which "handles our engagements with officials and politicians." The Group Public Affairs team leads and coordinates engagement with policymakers, ensuring "that all engagement activities are consistent with our overall climate change strategy." This indicates strong governance with clear monitoring processes and accountability structures in place, as well as identification of responsible parties for overseeing climate lobbying alignment.	3