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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Metlen Energy & Metals SA provides an unusually detailed picture of its climate-policy lobbying. It names a wide suite of specific measures it has engaged on, including the EU Emissions Trading System, the Carbon Border Adjustment Mechanism, the Energy Efficiency and Renewable Energy Directives, the Sustainable Finance Taxonomy, the Critical Raw Materials Act, the Temporary Crisis and Transition Framework, electricity-market design reforms and other Brussels initiatives. The company is equally clear about how it lobbies: it “interacts with policymakers by sending them our position papers and occasionally via direct meetings,” submits schemes “to the EC (DG COMP) for approval,” contributes to European Commission and national consultations, and, through Eurometaux, presents “concrete proposals” to Member-State and EU officials—thereby disclosing multiple direct and association-based channels as well as the precise targets of those efforts. Finally, Metlen spells out what it is trying to achieve. It seeks to relax Sustainable Finance Taxonomy thresholds it sees as “out of touch with technology availability,” urges energy-efficiency rules that focus on “improving the energy intensity of all processes at all levels,” calls for “well-targeted” and minimal renewable-energy subsidies, presses for aluminium to be listed as a “strategic raw material,” supports a stronger EU ETS only alongside robust carbon-leakage protections, and proposes a “Green Pool” scheme to underpin renewable PPAs for electro-intensive users. This combination of named policies, specified mechanisms and clearly articulated desired outcomes demonstrates a comprehensive level of transparency in the company’s climate-related lobbying disclosures.
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4
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| Overall Assessment |
Comment |
Score |
| Moderate |
Metlen Energy & Metals indicates that it has an internal structure for keeping its advocacy in step with its climate strategy, but the public detail remains limited. The company explains that "our company’s positions are based on decisions taken in the internal Committees (where the upper management participates), and all of our engagement activities must be consistent with the company’s positions and targets, including the climate targets," signalling a defined rule that guides direct policy engagement back to board-level endorsed positions. Oversight is at least partly formalised: a Board-level "Sustainability Committee was established… to assist the Board of Directors in… overseeing the implementation of responsible and ethical business conduct," and these committees are the forum where lobbying positions are decided, suggesting a governance body with review responsibility. In addition, the company provides a transparency mechanism by ensuring "all of our company’s responses to European Commission consultations are publicly available on the Commission’s portal," which demonstrates some monitoring of its direct interactions with policymakers. However, the disclosure does not describe any systematic process for assessing or managing the climate-policy alignment of industry or trade-association memberships, no periodic audit or public report of lobbying alignment is mentioned, and no individual executive is explicitly named as accountable for lobbying oversight. Consequently, while the evidence shows a policy and a committee-based oversight framework for aligning direct engagement with climate targets, the overall process is only moderately detailed and incomplete on indirect lobbying and monitoring specifics.
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2
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