Voestalpine AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	voestalpine AG provides a relatively detailed picture of the climate-policy files it works on and the results it is seeking. It explicitly names several instruments at the centre of its engagement, including the “EU Emissions Trading System (EU ETS),” the “Carbon Border Adjustment Mechanism (CBAM),” elements of the EU “Fit for 55” package, the “European Green Deal,” and national measures such as Austria’s “Expansion of Renewables Act (EAG)” and “Emissions Allowances Act (EZG).” The company also explains how it seeks to influence these files. It describes “constant talks—directly and via industry associations—with political decision makers,” participation in “consultations at the EU level,” and work in “various working groups and committees” of organisations such as EUROFER and ResponsibleSteel, and it points to its registration in lobbying lists (EU Transparency Register 189510925414-06 and Austria’s LIVR-00925). While these references reveal several concrete mechanisms—direct dialogue, written consultation submissions and association advocacy—and identify the EU institutions and Austrian authorities as targets, they stop short of naming individual ministries or lawmakers. voestalpine is clear about what it wants from these engagements. It calls for “100% free certificates for the ‘best’ companies based on real production,” seeks access to “capital to develop new technologies for climate protection” through instruments such as the EU ETS Innovation Fund and Important Projects of Common European Interest, and emphasises the need for “green energy in adequate quantities and at reasonable costs” as well as measures that “protect exposed industries from carbon leakage.” Collectively, these statements spell out specific legislative or funding outcomes the company is lobbying for rather than simple aspirations. Because the company names multiple concrete policies, discloses several lobbying channels and their governmental targets, and articulates distinct policy outcomes, its overall transparency on climate-related lobbying can be characterised as strong, though there is still room for greater precision around individual policymaker targets.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Voestalpine discloses several elements that indicate a structured, though still partial, approach to governing its climate-related lobbying. It has introduced a dedicated “Lobbying Code of Conduct” that "regulates dealings with stakeholders in Austria as well as in Europe and internationally" and applies to "all members of the management boards, the managing directors, and the non-executive employees", with the additional requirement that "care must be taken to ensure in cases where voestalpine’s lobbying activities are supported by third parties that the latter commit to compliance with the Lobbying Code of Conduct." For climate matters, the company explains that "voestalpine group’s environmental and climate change activities are coordinated by the department Group Environment … [and] the results are constantly reported and approved by voestalpine's board," while "the head of the department for strategic environmental management meets regularly with members of voestalpine's board in order to ensure a consistent climate change strategy over all group companies." These statements show a defined process and identify the Board as the approving body, suggesting oversight of how engagement activities, including lobbying, align with climate strategy. The company also confirms a "public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement," signalling an intention to align advocacy with climate goals. However, the disclosures do not describe any systematic review or audit of how its direct lobbying and its participation in "bodies serving advocacy groups, trade associations, and lobbying campaigns" are assessed for climate alignment, nor do they provide examples of modifying or ending memberships where misalignment is found. The absence of publicly available assessments or detailed monitoring criteria limits transparency into the effectiveness of the governance framework.	2