Metsa Board Oyj

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Metsä Board Oyj has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names several specific climate-related policies it has engaged with, including the "EU waste framework directive (WFD) and Packaging and packaging waste directive (PPWD," "EU taxonomy (climate change mitigation and adaptation, circular economy)," "Revision of the renewable energy directive (RED II)," "Revision of the European Emissions Trading system (ETS) regulation," "Finnish climate and energy strategy," and "Regulation of deforestation free products." Additionally, it references the EU's climate neutrality objective, the industrial carbon management framework - COM(2024) 62 final, and other policies such as the Ecodesign of Sustainable Products Regulation, LULUCF, ETS, and RED III, demonstrating transparency in naming the policies and frameworks it seeks to influence. Metsä Board provides detailed information about its lobbying mechanisms and targets, stating that "Corporate Affairs representatives meet policy makers and other stakeholders" to discuss the impact of proposed policy initiatives and promote coherent regulation. It identifies specific targets, such as EU policymakers, Nordic and German policymakers, and mentions participation in "industry and trade association working groups" as part of its indirect lobbying mechanisms. Furthermore, the company has been transparent about the specific outcomes it seeks through its lobbying efforts, such as creating a science-based definition for renewable carbon, promoting bio-CCU to replace fossil carbon sources, accelerating technological bio-CCUS, and fostering biobased materials under the EU Biotech and biomanufacturing initiative. It also advocates for the recognition of renewable materials as circular inputs in product regulation and the development of an EU roadmap for bio-CO2 in climate policies. These disclosures clearly articulate desired policy changes and outcomes, demonstrating a high level of transparency in its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Metsä Group demonstrates strong governance in its climate lobbying processes through a structured approach to advocacy and stakeholder engagement. The company's Executive Board "sets group wide policies, defines sustainability targets and advocacy priorities and monitors the progress," indicating a clear oversight mechanism. Sustainability targets are "approved by the Board of Directors and aligned with the strategy," showcasing integration with broader organizational goals. The Corporate Affairs team plays a central role, with the SVP Corporate Affairs reporting directly to the CEO and President, ensuring accountability and alignment at the highest levels. Additionally, the VP Sustainability is part of the Corporate Affairs team, "further strengthening the integration of sustainability commitments to policy-related activities." The company coordinates its activities globally, with representatives focusing on policy issues at the EU level, the Nordics, and Germany, and engages experts in working groups to interact with policymakers and trade associations. Internal coordination is managed by Corporate Affairs, and local-level activities are aligned with group-level policies through environmental management systems applied at all production units. Regular reporting mechanisms are in place, as progress in sustainability targets, including climate-related advocacy, is "regularly reported to the Board of Directors every quarter," ensuring accountability and oversight. While the evidence does not mention a detailed lobbying audit or comprehensive review of alignment across trade associations, the governance processes described are robust and well-defined, covering monitoring, management, and oversight of climate lobbying activities.	3