LyondellBasell Industries NV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	LyondellBasell appears to have a robust climate lobbying governance process with clear mechanisms for monitoring both indirect and direct lobbying activities and multiple oversight bodies. It publishes its first Climate Advocacy Report which describes our approach to climate advocacy including detailing our climate policy positions, setting out our approach to participating in trade associations, and publishing our first-ever review and evaluation of trade association alignment with our climate policy positions, in which it assesses its ten most important trade associations plus the World Economic Forum, defining each as aligned, partially aligned, or misaligned and committing to provide an updated assessment every two years. The company explains that it takes action where misalignment is identified, including reaffirming its position internally, publicly dissent[ing] or withdrawing our membership, and it also outlines a formal direct-lobbying alignment process whereby it solicits input from relevant business and functional departments, has Key issues ... discussed and prioritized by members of senior management, and ensures our engagement activities are aligned with these positions. Oversight is clearly assigned to specific roles and bodies: our engagement, including public policy advocacy directly and through trade associations, is subject to oversight by LyondellBasell senior management and our CEO, the Director of Government Relations and Vice President of Government Relations oversee trade association memberships, the LYB PAC Board governs PAC activities (with an internal audit every four years), and the Executive Vice President, Sustainability & Corporate Affairs along with a Policy Committee reviews and approves the companys U.S. policy on political expenditures. The company does not disclose any external third-party validation of its lobbying alignment audit, though it embeds transparency, accountability and biennial reviews into its governance framework. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

LyondellBasell appears to have a robust climate lobbying governance process with clear mechanisms for monitoring both indirect and direct lobbying activities and multiple oversight bodies. It publishes its first Climate Advocacy Report which describes our approach to climate advocacy including detailing our climate policy positions, setting out our approach to participating in trade associations, and publishing our first-ever review and evaluation of trade association alignment with our climate policy positions, in which it assesses its ten most important trade associations plus the World Economic Forum, defining each as aligned, partially aligned, or misaligned and committing to provide an updated assessment every two years. The company explains that it takes action where misalignment is identified, including reaffirming its position internally, publicly dissent[ing] or withdrawing our membership, and it also outlines a formal direct-lobbying alignment process whereby it solicits input from relevant business and functional departments, has Key issues ... discussed and prioritized by members of senior management, and ensures our engagement activities are aligned with these positions. Oversight is clearly assigned to specific roles and bodies: our engagement, including public policy advocacy directly and through trade associations, is subject to oversight by LyondellBasell senior management and our CEO, the Director of Government Relations and Vice President of Government Relations oversee trade association memberships, the LYB PAC Board governs PAC activities (with an internal audit every four years), and the Executive Vice President, Sustainability & Corporate Affairs along with a Policy Committee reviews and approves the companys U.S. policy on political expenditures. The company does not disclose any external third-party validation of its lobbying alignment audit, though it embeds transparency, accountability and biennial reviews into its governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	LyondellBasell Industries N.V. provides a highly detailed picture of its climate-policy advocacy. It names multiple, identifiable pieces of legislation it has engaged on, including the EU “Fit for 55” package – notably the “Regulation establishing a Carbon Border Adjustment Mechanism”, forthcoming changes to the EU Emissions Trading System, and the “EU Renewable Energy Directive (REDIII)” – as well as national decarbonisation road-maps and subsidy instruments in France, Germany and the Netherlands, and U.S. state greenhouse-gas reduction and clean-energy standards. The company explains exactly how it seeks to influence these measures: it undertakes “direct engagement with policymakers, including ‘principal MPs in the European Parliament’”, holds “discussions with governments on EU- and national level”, invites regulators to its sites, and works indirectly through trade associations such as Cefic, BusinessEurope, the American Chemistry Council and its own LYB PAC, thereby identifying both the mechanisms used and the specific targets of those efforts. LyondellBasell is also clear about what it wants to achieve. It “supported the introduction of a CBAM as a tool to fight carbon leakage in Europe”, seeks to “increase the availability of high quality low carbon hydrogen irrespective of its production route” and obtained “an exemption of hydrogen derived from decarbonizing industrial gases in the preliminary agreement” of REDIII; it presses for funding schemes and subsidies to underwrite large-scale GHG-reduction projects, continued free allowances during the ETS phase-out, and carbon-pricing rules that are “technology and material neutral” and guard against competitiveness risks. This level of specificity across policies, mechanisms and desired outcomes demonstrates comprehensive transparency in the company’s climate-related lobbying disclosures.	A