Pegasus Hava Tasimaciligi AS

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Pegasus Hava Tasimaciligi AS provides a fair amount of detail on its climate-related lobbying, but this transparency is concentrated on a single policy initiative. It clearly identifies the policy focus—"the inclusion of the aviation industry in the Turkish MRV system"—and names the responsible authority, the Turkish Directorate General of Civil Aviation. The company also spells out several concrete lobbying methods, noting that it "took an active part in roundtable discussions and meetings," "engage[d] with [the] Directorate General of Civil Aviation directly," and "contributed by giving feedback" on the draft regulation, thereby describing both direct interactions and formal consultations with a clearly named target. In terms of objectives, Pegasus explains that it sought to "actively participate in the studies on the creation of the local MRV system in the aviation sector" and to influence how the draft regulation was framed, demonstrating that the company had a defined policy outcome in mind even if it relates to a single legislative process. Overall, the disclosure demonstrates solid transparency on the mechanisms used and the aim pursued, but it is limited to one policy area and therefore provides only moderate breadth of insight into the company’s wider climate-policy lobbying activity.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Pegasus Hava Tasimaciligi AS provides only a brief description of how it tries to keep policy engagement in line with its climate goals: it states that "employees who advise/advise senior management on strategy are also those who engage with third parties" so that “the people involved in the fight against climate change display the same attitude in every platform.” This indicates some internal coordination to ensure that external advocacy reflects the company’s climate strategy, but the disclosure offers no details about a formal review process, monitoring criteria, or corrective actions, nor does it identify any specific individual, board committee, or governance body responsible for overseeing lobbying alignment. Apart from noting that staff "provid[e] opinions and suggestions to ensure the supply of low-emission SAF and to introduce legal regulations," the company does not disclose how it governs or evaluates either direct lobbying or its involvement in trade associations. Overall, the information suggests only a limited, informal approach to lobbying governance, with many key elements—such as documented procedures, oversight structures, and reporting on alignment—remaining undisclosed.	1