Wizz Air Holdings Plc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Wizz Air discloses a highly detailed picture of its climate-policy lobbying. It names a wide range of specific measures it has engaged on, including the EU Emissions Trading System Aviation file, the European Commission’s ReFuelEU Aviation proposal, the Energy Taxation Directive, the Single European Sky 2+ reform, and national Sustainable Aviation Fuel (SAF) strategies in Austria and Hungary, as well as its broader involvement with the EU Fit for 55 package. The company also explains how it tries to influence those files: a dedicated EU Affairs Manager conducts “regular engagement with policy makers in the EU”, the airline is listed in the EU Transparency Register and works through public-affairs consultancies such as Hume-Brophy and Penta, it takes part in formal consultations, sits on the UK government’s JetZero Council (“The Company is a member of the two delivery groups of the UK government’s main advisory body on sustainable aviation, the JetZero Council”), and participates in the UAE Aviation Environment Working Group, together demonstrating both direct and indirect lobbying routes and clearly identified targets. Finally, Wizz Air is explicit about the outcomes it seeks, backing the extension of ETS coverage to all EEA departures, the early phase-out of free allowances, and the creation of SAF allowances (“We agree with the introduction of the SAF allowances into ETS, to incentivise SAF uptake across Europe”); advocating for a book-and-claim system in ReFuelEU and “significant investment support”; supporting SES2+ to cut emissions (“We could further reduce our emissions if the SES2 is effectively carried out”); while opposing aspects of the Energy Taxation Directive on the grounds that “double taxation needs to be avoided” and “Wizz Air cannot support an additional financial burden to be introduced for airlines”. This level of specificity across the policies addressed, the mechanisms used, and the concrete policy changes sought demonstrates comprehensive transparency in the company’s climate-related lobbying disclosures. 4
Lobbying Governance
Overall Assessment Comment Score
Limited Wizz Air’s disclosures illustrate minimal governance around its lobbying activities and no tailored mechanism to align advocacy with climate objectives. The company states that "Wizz Air itself does not make any political donations and does not incur any political expenditure" and that "Employees are also obliged to follow the Wizz Air Code of Conduct and Anti-Bribery Policy," with "Any risk of significant violation of these policies and procedures ... escalated by the Corporate and ESG Officer to the Audit and Risk Committee." It highlights collaboration "with Penta (formerly Hume-Brophy) on advocacy issues in the European Union, with a special focus on climate or other regulation impacting aviation" and confirms it "conduct[s] engagement activities in line with the goals of the Paris Agreement" by answering "Yes" to having such a public commitment. Beyond noting its inclusion in the "EU Transparency Register" and requiring Officer approval for non-financial support to events, Wizz Air does not disclose a formal policy, regular review process, or designated board or committee oversight explicitly charged with ensuring that its direct and indirect lobbying activities advance its climate change strategy. 1