LyondellBasell Industries NV

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	LyondellBasell Industries N.V. has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly named specific climate-related policies and regulations it has engaged with, such as the EU Emissions Trading System (EU ETS), the Carbon Border Adjustment Mechanism (CBAM), and the European Renewable Energy Directive (REDIII). Additionally, it has disclosed its engagement with national governments in France, Germany, and the Netherlands on decarbonization roadmaps and subsidy instruments linked to GHG-reduction technologies. LyondellBasell has also provided detailed information about its lobbying mechanisms, including direct engagement with policymakers such as Members of the European Parliament, indirect engagement through trade associations like Cefic and BusinessEurope, and participation in initiatives like the Alliance to End Plastic Waste. The company has outlined its process for public engagement, including prioritizing issues through senior management and aligning activities with its public policy principles. Furthermore, LyondellBasell has been transparent about the specific outcomes it seeks, such as advocating for increased availability of low-carbon hydrogen under REDIII, supporting the CBAM to address carbon leakage, and securing funding schemes to support high capital investments for emission reduction technologies. These disclosures reflect a clear articulation of the company's lobbying efforts, mechanisms, and desired policy outcomes, demonstrating a high level of transparency in its climate advocacy.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	LyondellBasell demonstrates a comprehensive climate lobbying governance process, as evidenced by its detailed Climate Advocacy Report. The company has published its first-ever review and evaluation of trade association alignment with its climate policy positions, stating, "This report 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." This review includes a methodology for assessing trade associations, categorizing them as aligned, partially aligned, or misaligned, and outlining actions to address misalignments, such as reaffirming positions, advocating for changes, or withdrawing membership. For example, the report notes, "Where misalignment is identified, we take action. For example, our representatives may reaffirm LyondellBasell's position and advocate within the organization for a change in position. If there is a material misalignment on a priority policy issue, we may publicly dissent from the trade association before withdrawing our membership." The company also commits to updating this assessment every two years, indicating ongoing monitoring and accountability. Additionally, LyondellBasell has identified responsible parties for overseeing climate lobbying alignment, such as its representatives on various trade association committees and boards. For instance, "LyondellBasell is a member of the ACC Executive Committee, and LyondellBasell representatives sit on multiple committees," and similar roles are noted for other associations like BusinessEurope and the European Chemical Industry Council (Cefic). The report also provides transparency into the financial contributions to trade associations, further enhancing accountability. The company's governance framework includes clear alignment with the goals of the Paris Agreement and policies supporting net-zero emissions by 2050, as well as specific positions on hydrogen, CCUS, emerging technologies, renewable electricity, and carbon pricing. The report states, "Our global climate policy positions serve as a framework to guide LyondellBasell's advocacy with governments and within industry associations. These climate policy positions also serve as the basis for our review of industry associations in this report." This indicates a robust governance process that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms and accountability structures in place.	4