UPM-Kymmene Oyj

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	UPM-Kymmene Oyj demonstrates a comprehensive level of transparency in its climate lobbying activities. The company explicitly identifies specific climate policies it has engaged with, such as the 'EU Taxonomy,' the 'EU Commission's ILUC proposal on biofuels,' the 'Renewable Energy Directive (REDIII),' and the 'EU Emission Trading Scheme (ETS).' It also provides detailed information about its focus areas, including 'stringent rules to reduce transport emissions,' 'sustainable forest management,' and 'renewable circularity.' UPM discloses its lobbying mechanisms, including direct engagement with EU institutions, member state governments, and participation in consultations. It also highlights its indirect lobbying through industry associations like the Confederation of European Paper Industries (CEPI) and its registration in transparency registers, such as the EU's transparency register and the German Lobbyregister. Furthermore, UPM is transparent about the specific outcomes it seeks, such as advocating for 'a stronger mandate for advanced biofuels within the REDIII,' 'technology neutrality and simplification of the regulatory framework,' and 'a level playing field in energy taxation and subsidies.' These disclosures clearly outline the company's desired policy changes and objectives, showcasing a high level of transparency in its climate lobbying efforts.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	UPM describes a process for aligning its indirect lobbying through trade associations with its climate commitments, indicating that "UPM is a member of various joint industry, sustainability and trade associations and networks. This is one way of influencing and monitoring the policies for being aligned with our strategy and climate pledge." The company also outlines elements of its governance structure by explaining that "UPM Public Affairs is led by the Vice President, Public Affairs. He reports to the Executive Vice President of Marketing, Sustainability and Communications, who is a member of the Group Executive Team," while mentioning "topic specific steering groups" and regular reviews by the Group Executive Team. Although these disclosures show that UPM has identified responsible roles and a policy focus on climate in its lobbying activities, the company has not provided a detailed account of how these activities are monitored or enforced, and it does not publish a detailed lobbying audit. Nevertheless, this indicates that UPM has established a reasonably clear governance approach for overseeing lobbying alignment with its climate strategy.	3