TORM PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	TORM PLC provides a high level of detail on the climate-policy issues it engages on. It identifies several concrete measures under discussion, including the “EU Emissions Trading System (EU ETS),” the “FuelEU Maritime Initiative,” and the forthcoming revision of the IMO’s “Carbon Intensity Indicator (CII)” rules, and explains that it follows and seeks to influence these policy processes through Danish Shipping and other forums. The company also sets out the channels it uses: it “aims to impact the decision-making in IMO in relation to ongoing discussions on the implementation of CO2-related regulations” through active participation in Danish Shipping, has “contributed input to the IMO on the upcoming revision of the CII regulation,” and has formed an internal cross-functional task force to engage EU policymakers on the EU ETS, thereby naming both the mechanisms (industry association work, direct submissions, specialised internal team) and the targets (IMO and EU institutions). On desired outcomes, TORM is explicit that it “welcomes the EU ETS implementation and its CO2 pricing” and wants to shape the IMO’s CII revision, stating that these steps will “support the work towards a greener future” and give the company a commercial advantage. While the company does not set out detailed amendments it seeks, it nevertheless makes clear its support for the EU ETS and its intention to influence the CII update, demonstrating consistent and reasoned policy positions. Taken together, these disclosures show strong transparency across policies lobbied, mechanisms employed, and the climate-policy outcomes the company seeks.	3

Lobbying Governance

Overall Assessment	Comment	Score
None	TORM PLC’s disclosures focus predominantly on climate-related risk management, emphasizing that "The Risk Committee has oversight of climate-related risks and opportunities through its responsibility for the governance of TORM’s enterprise risks," noting that "TORM manages policy and legal risks by monitoring regulatory developments in the markets where it operates," and that "The Audit Committee has oversight of financial reporting, external audit, internal controls, and risk management. It also oversees non-financial reporting, including the annual sustainability report." These statements illustrate a clearly defined risk-governance framework, but we found no evidence of any dedicated governance process for lobbying: the company does not disclose a policy, review procedure, or sign-off mechanism for its direct advocacy or its indirect engagement via trade associations, nor does it identify any individual or formal body assigned to oversee lobbying alignment with its climate objectives.	0