Uniper SE

Sign up to access all our data and the evidence and analysis underlying our overall scores. Once you've created an account, we'll get in touch with further details:

Sign Up

Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Uniper SE provides a highly detailed picture of its climate-policy lobbying. It identifies numerous specific measures it has tried to influence, including the EU Emissions Trading System and its Market Stability Reserve and Back-loading mechanisms, the consultation on integrating Greenhouse Gas Removals into the UK ETS, the EU Taxonomy screening criteria, the coal phase-out legislation in the Netherlands and Germany, EU methane-emissions regulation, and the UK Department for Business, Energy and Industrial Strategy’s framework for power CCUS projects. The company also explains how it lobbies and who it lobbies: it submits written consultation responses to the UK ETS authority ("ukets.consultationresponses@energysecurity.gov.uk"), participates in the Welsh Hydrogen Reference Group, holds "discussions with the European Commission" on EU ETS reforms, makes formal submissions to BEIS on CCUS business models, and engages policymakers through "speeches and talks with politicians" by its Political Affairs team. Finally, Uniper sets out the concrete outcomes it seeks, such as "strengthening of the EU-ETS", securing compensation for early coal-plant closures in the Netherlands, inclusion of natural gas as a transitional activity and a hydrogen carbon-intensity threshold in the EU Taxonomy, a "phased-in approach, with no performance-based requirements in the early stage" of EU methane rules, and UK ETS changes that "prioritise the inclusion of permanent removals" and allow international GGR credits. The combination of clearly named policies, specific engagement channels with identified public-sector targets, and explicit policy positions and desired changes demonstrates a comprehensive level of transparency in Uniper’s climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Uniper discloses high-level sustainability oversight structures but provides very limited information on how it governs climate-related lobbying. It states that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and that “Discussions on the decarbonization strategy and the concrete measures were increasingly held in 2021 […] through the Sustainability Council”, indicating an intention to align external engagement with its climate strategy. Governance bodies such as the Sustainability Committee of the Supervisory Board, which “monitors the effectiveness of Uniper’s ESG policies and procedures and the sustainability strategic plan (SSP)”, and the Sustainability Council, which is “a cross-functional body that meets on a quarterly basis to oversee the implementation of Uniper’s sustainability strategy and governance framework”, are clearly identified. However, the evidence does not specify whether these bodies review or approve direct lobbying positions, monitor the company’s interactions with policymakers, or assess the climate-policy stances of trade associations; nor does it describe any formal process for correcting or exiting misaligned associations. We found no disclosure of a dedicated lobbying policy, no description of alignment checks for direct or indirect advocacy, and no published review or audit of lobbying activities. Consequently, while there is a general commitment to Paris-aligned engagement and some senior-level ESG oversight, the company does not disclose a concrete governance framework for climate lobbying alignment beyond these statements, indicating only limited governance in this area.	1