Repsol SA

Repsol's climate policy positions Repsol has recently revised its five high-level [principles that guide our climate policy](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2023/repsol-climate-policy-positions-2023.pdf) **[positions. They represent the high-level](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2023/repsol-climate-policy-positions-2023.pdf)** framework on climate change and energy transition for Repsol's advocacy with different stakeholders, from governments to international organizations, and they are used to assess the alignment of the industry associations with the company's positions. Our positions will continue to evolve in consistency with scientific evidence, multilateral agreements, regulations, and our own business transformation efforts to achieve net zero emissions by 2050. [...] Review Methodology We have implemented an assessment approach that entails the following steps[4]: 1. **Identify main initiatives and associations.** 2. Assess whether the associations positions **are consistent with both the fulfilment of the** goals of the Paris Agreement and our climate policy positions. 3. Act to address all cases of potential misalignment. 4. **Monitor and review lobbying activities** and alignment with Repsol's climate positions once a year, disclosing publicly the results of the assessment. [...] Taking a Position Depending on the level of alignment, the company will take the necessary measures to bring the diverging climate positions and strategies closer together, considering the views and perspectives of each party: - For aligned associations we will maintain our engagement and collaborate constructively on policies related to climate change and the energy transition. - For partially aligned associations, we will continue to engage with an open and constructive dialogue to promote energy transition policies that support the goal of the Paris Agreement. As a rule, we see added value in our memberships, and we firmly believe we can have a greater impact remaining part of the associations. - We will terminate our membership non-aligned associations. We will leave open the possibility of resuming relationships in the future in case our positions to climate change realign later on. [...] Results and Next Steps Out of the 37 industry associations reviewed, our assessment has led to: - 35 aligned associations, of which five have been reviewed for the first time (Asociación Española de Hidrógeno, International Air Transport Association, Efuel Alliance, American Clean Power, Asociación de Generadoras de Chile). - 2 partially aligned associations (API and OCIMF). - No non-aligned associations. [...] Addressing Misalignment We have found some misalignment with API and OCIMF and continue to work towards convergence in those areas where there are some differences in climate-related positions. We will continue to advocate for inclusive climate policies that contribute to achieving the goals of the Paris Agreement and net zero emissions by 2050, in line with an orderly energy transition that ensures sustainable, affordable, and secure energy supply. We will continue reviewing association developments on climate change and our own positions annually for early identification of potential misalignments and commit to publishing an updated report each year.

Not only are the CEO and members of the Executive Committee committed to engaging with ESG investors and proactively taking part in Repsol's, roadshows and meetings, this commitment is also shared by the Board of Directors. In this respect, the Lead Independent Director and chairman of the [Sustainability Committee, Mr. Mariano Marzo,](https://www.repsol.com/en/shareholders-and-investors/corporate-governance/board-of-directors/mariano-marzo-carpio/index.cshtml) and the Independent Non-Executive Director, Chairwoman of the Nomination Committee, Chairwoman of the Compensation Committee and Member of the Audit and Control [Committee, Ms. Aurora Catá, have also met with](https://www.repsol.com/en/shareholders-and-investors/corporate-governance/board-of-directors/aurora-cata-sala/index.cshtml) institutional investors during the past 12 months. [...] Following the approval of the 2024-2027 Strategic Update in February 2024, we submitted [our Energy Transition Strategy for a second](https://www.repsol.com/content/dam/repsol-corporate/en_gb/accionistas-e-inversores/informes-jga/2024/2024-energy-transition-strategy.pdf) shareholder advisory vote at our 2024 Annual General Meeting. This vote did not replace **the Board of Directors' responsibility for setting** **the Company's strategy, which, according to the** internal regulations and applicable legislation, is within its own competencies. The Board of Directors also monitored the outcome of the vote closely. [...] As part of this dialogue with our shareholders, [including, among others, the Climate Action](https://www.climateaction100.org/) **[100+ initiative, we submitted, for the first time,](https://www.climateaction100.org/)** our Climate Strategy for an advisory vote at our 2022 General Shareholders' Meeting, which gathered strong support. Since then, we have continued to actively engage with our main institutional shareholders, with the participation of the Chairman of the Sustainability Committee and Lead Independent Director, and the Independent Chairwoman of the Nomination and Compensation Committees, to share and discuss our energy transition strategy and our corporate governance practices.

We acknowledge the increasing demand from our stakeholders for enhanced transparency regarding corporate lobbying activities, particularly in the context of climate change and the energy transition. Investor initiatives, such as the Climate Action 100+ Net Zero Company Benchmark and the Global Standard on Responsible Corporate Climate Lobbying, have emerged to promote greater transparency in climate-related lobbying efforts undertaken by companies and industry associations. [...] We have implemented an assessment approach that includes the following steps[1]: **1. Identify main initiatives and associations.** **2. Assess whether the associations' positions are consistent with both the** fulfilment of the goals of the Paris Agreement and our climate policy positions. **3. Act to address all cases of potential misalignment.** **4. Monitor and review lobbying activities and alignment with Repsol's climate** positions once a year, disclosing publicly the results of this assessment. [...] The internal assessment process is carried out with the participation of several corporate areas (Sustainability, Institutional Relations, and Investors Relations) as well as incumbent businesses and regional teams. [...] Following the identification process, all publicly available policy and advocacy information on the industry associations is collected and analyzed, including a review of their websites, position letters, and social media. The associations are then approached to request other relevant information regarding their alignment with both the goals of the Paris Agreement and Repsol's climate change policies. [...] Depending on the level of alignment, the company will take the necessary measures to bring the diverging climate positions and strategies closer together, considering the views and perspectives of each party: - This process is applied to all associations, including those classified as aligned, to address any potential differences that could arise in the future. - For aligned associations, we will maintain our engagement and collaborate constructively on policies related to climate change and the energy transition. - For partially aligned associations, we will continue to engage in an open and constructive dialogue to promote energy transition policies that support the goal of the Paris Agreement. We will track alignment and will be transparent about where we find differences and always try to find opportunities to influence and collaborate. [...] We will terminate our membership in non-aligned associations. We will leave the possibility of resuming the relationship open in case our positions on climate change re-align in the future. [...] In the European Union and the United States, we also report on costs related to lobbying activities, in accordance with the requirements and guidelines set out in the EU Transparency Register and the US Lobbying Disclosure Act. All this information reported by the company is made public.

Repsol has a governance structure for managing matters related to climate change led by the Board of Directors. The Board approves and monitors the decarbonization strategy, which is part of the Company's strategy, and ensures that the sustainability and energy transition targets and indicators are met. This involves tracking metrics, emissions and carbon intensity reduction targets, technological innovations, and the alignment of the investment proposals with the energy transition goals. [...] The Executive Committee and the Board review the alignment of the investment proposals with the energy transition and the Company's decarbonization path based on specific reports drawn up by the Sustainability Division. These reports reflect the positive, neutral, or negative impact of each investment proposal on Repsol's Carbon Intensity Indicator, a metric that analyses the Company's progress toward decarbonization. [...] The Sustainability and the Audit and Control Committees of the Board of Directors also supervise the reporting and execution of the climate change strategy and the Carbon Intensity Indicator management and compliance. Specifically, in 2024 the Sustainability Committee held five meetings and reviewed the following aspects, among others: [...] Review of the report on Repsol's participation in industry initiatives and associations.

The Sustainability Committee and the Audit and Control Committee, as well as the Executive Committee, regularly monitor the data on the implementation of the climate change strategy and progress regarding compliance with the Carbon Intensity Indicator. Specifically, in 2023 the Sustainability Committee reviewed the following aspects, among others: - Fulfillment of the energy transition targets by the end of 2023. - The decarbonization strategy. - The methodology for qualifying investments to ensure they are in line with the energy transition (Carbon Intensity Indicator). - Targets and summary of investments aligned with the energy transition at year-end 2022. - Climate scenarios and the evolution of the Carbon Intensity Indicator. - Greenhouse gas (GHG) emissions map for 2022. - Non-financial reporting framework. - Company's 2030-2050 scenarios for energy transition resilience. - Climate change risk analysis (2022-2050). - Participation in industry initiatives and associations and their alignment with the Company's climate position. - Main implications for Repsol of the COP-28 agreements. Likewise, the Audit and Control Committee reviewed the non-financial information published in the Management Report, as well as the non-financial risk control and management systems[6]. The Executive Committee is directly responsible for managing matters related to the energy transition: - It oversees and proposes to the Board of Directors the Company's strategy aligned with the energy transition, as well as the scenario analysis in the long term (2031-2050). - It approves and assesses the targets, budgets, and annual investment plans. - It approves the methodology for the qualification of investments to ensure that it is in line with the energy transition. - It approves potential changes in the Carbon Intensity Indicator calculation methodology and monitors (at least once a year) the progress made towards achieving the targets established for this key indicator. - It assesses the investment proposals and their impact on the Carbon Intensity Indicator. - It oversees the risk management policies and the emerging risks and climate change map periodically presented by the Audit, Control, and Risk Department. The general business departments and divisions with the most significant impact on the energy transition strategy collaborate and hold regular coordination meetings. They review ongoing projects related to managing climate change risks and opportunities, and specialized teams advise them on climate-related issues. Around 150 full-time employees work on climate and energy transition issues, distributed across corporate functions (sustainability, legal, risk management, strategy, technology, investor relations, communication, institutional relations, etc.) and business units. Moreover, meeting energy transition targets has a direct impact on the variable remuneration of all employees."
"Repsol takes the view that lobbying activities should be undertaken transparently and in compliance with current legislation. Accordingly, the Company reports such activity in all areas where formal registration is required, and pursuant to the requests made by competent authorities. It is public and accessible. In particular, activity is registered in the European Union, in the USA at federal level, and in Canada at federal and provincial level (Alberta). [...] For more information and links to the official lobbying registration pages, see www.repsol.com.

We acknowledge the increasing demand from our stakeholders for enhanced transparency regarding corporate lobbying activities, particularly in the context of climate change and the energy transition. In this sense, investor initiatives, such as the Climate Action 100+ Net Zero Company Benchmark and the Global Standard on Responsible Corporate Climate Lobbying, have emerged to promote greater transparency in climate-related lobbying efforts undertaken by companies and industry associations. [...] We regularly assess the alignment between key associations and our climate policy positions. As a result, the company publishes an annual report on Repsol's participation in trade associations[18]. For those partnerships that are partially aligned according to our assessment, our goal is to promote, through dialogue, energy transition policies that support the goal of the Paris Agreement. If the assessment is not aligned, we will terminate our participation, leaving open the possibility of resuming the relationship if our positions on climate change align again in the future. In 2023, we reviewed 37 industry associations. Our assessment led to the identification of: - 35 aligned with the Paris Agreement and our climate policy positions, of which five have been revised for the first time (Asociación Española de Hidrógeno, International Air Transport Association, Efuel Alliance, American Clean Power, Asociación de Generadoras de Chile). - 2 partially aligned associations (API and OCIMF). - No non-aligned associations [...] Repsol has established five principles that define our climate policy positions[19]. They represent the global framework of climate change and energy transition positions that is the basis for Repsol's advocacy with different stakeholders, from governments to international organizations. We also assess the alignment with these same principles of the industry associations in which Repsol participates.

The Sustainability Committee supervises and periodically monitors the decarbonisation roadmap and compliance with related plans and targets, as well as emerging risks relating to energy transition and climate change. The Chair of the Committee reports to the Board of Directors on the development of its actions on a regular basis. Furthermore, at least once a year, the Committee assesses its functioning and the quality and effectiveness of its work, reporting the outcome of this assessment to the plenary session of the Board. EXAMPLE of climate-related decision: In 2022, the committee held 5 meetings and reviewed, among other issues, Fulfillment of the energy transition targets by the end of 2022. •Quantification of investments to ensure they are in line with the energy transition. • CO2 emission allowances. • Greenhouse gas (GHG) emissions map for 2022. • Non-financial reporting frameworks. • 2030-2050 business scenarios. • Participation in industry initiatives and associations and their alignment with the Company's climate position. • Results from COP27

The Sustainability Committee supervises and periodically monitors the decarbonisation roadmap and compliance with related plans, as well as emerging risks relating to energy transition and climate change. The Chair of the Committee reports to the Board of Directors on the development of its actions on a regular basis. Furthermore, at least once a year, the Committee assesses its functioning and the quality and effectiveness of its work, reporting the outcome of this assessment to the plenary session of the Board. EXAMPLE: In 2020, the committee held 4 meetings and reviewed, among other issues, the climate change exposure in the corporate risk management processes, as well as the Company's system for managing these risks and the respective mitigation measures. Other issues discussed were TCFD, CDP, climate change strategy, non-financial reporting and Repsol's alignment with trade associations.

We acknowledge the increasing demand from our stakeholders for enhanced transparency regarding corporate lobbying activities, particularly in the context of climate change and the energy transition. In this sense, investor initiatives, such as the Climate Action 100+ Net Zero Company Benchmark and the Global Standard on Responsible Corporate Climate Lobbying, have emerged to promote greater transparency in climate-related lobbying efforts undertaken by companies and industry associations. [...] We regularly assess the alignment between key associations and our climate policy positions. As a result, the company publishes an annual report on Repsol's participation in trade associations[18]. For those partnerships that are partially aligned according to our assessment, our goal is to promote, through dialogue, energy transition policies that support the goal of the Paris Agreement. If the assessment is not aligned, we will terminate our participation, leaving open the possibility of resuming the relationship if our positions on climate change align again in the future. In 2023, we reviewed 37 industry associations. Our assessment led to the identification of: - 35 aligned with the Paris Agreement and our climate policy positions, of which five have been revised for the first time (Asociación Española de Hidrógeno, International Air Transport Association, Efuel Alliance, American Clean Power, Asociación de Generadoras de Chile). - 2 partially aligned associations (API and OCIMF). - No non-aligned associations [...] Repsol has established five principles that define our climate policy positions[19]. They represent the global framework of climate change and energy transition positions that is the basis for Repsol's advocacy with different stakeholders, from governments to international organizations. We also assess the alignment with these same principles of the industry associations in which Repsol participates.

###### Update of Repsol's participation on industry associations

Repsol's climate policy positions

[Repsol's updated climate policy positions have](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2022/repsol-climate-policy-positions-2022.pdf)
been published on our website in July 2022

In an explicit commitment to transparency
and recognising investor interest in this matter,
Repsol has established five principles that define
our climate policy positions.

They represent the global framework of climate
**change and energy transition positions for**
Repsol's advocacy with different stakeholders,
from governments to international organisations,
and they are used to assess the alignment of the
industry associations to which Repsol belongs
with the company's positions.

Our positions will continue to evolve in line
with scientific evidence, multilateral agreements,
regulations, and other key drivers of global
progress to achieve net zero emissions by 2050.

###### 2022 Assesment

[In this assessment, we have reviewed](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2022/participation-in-associations-climate-review-update.pdf)
**32 initiatives and associations selected**
in accordance with the following criteria:

a) Links with the energy sector.

b) Regions or countries where Repsol has

significant business activities.

c) Relevance in relation to climate change matters.

Using publicly available information,
the associations were assessed to be aligned,
**partially aligned, or not aligned with our**
climate-related position.

**Aligned: the association expressly states**
its commitment to adhere to the objectives
established in the Paris Agreement and
its actions are consistent or not in conflict
with Repsol's climate policy positions.

**Partially aligned: the association has not defined**
a public position regarding the Paris Agreement
or Repsol has raised some concerns about its
position in relevant climate matters.

**Not aligned: the association has a public**
position that is contrary to or in significant
conflict with Repsol's climate policy positions
and/or the Paris Agreement

[Since the first assessment of Repsol's](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2019/assessing_repsol_participation_initiaves_associations_climate_change_tcm14-181638.pdf)
participation in industry initiatives
and associations, we have added
**new associations that fit with the selected**
criteria and eliminated those of a highly
technical scope, think tanks, and non-affiliate
relationships such as NGOs or investor
groups, as well as government initiatives
and committees.

As an overall conclusion, we found that most
of our memberships are aligned with Repsol's
climate positions. Out of the 32 associations
**reviewed, 30 are aligned and 2 partially aligned.**

We collaborate in these associations
and initiatives and encourage the development
of their lines of action in accordance with
our climate position, paying membership fees
and participating in working groups
and collaborative events they organise.

The associations identified as partially
**aligned in 2021 have been re-evaluated,**
and we have established an open
and constructive dialogue to encourage
greater involvement, collaboration, and
commitment in their actions against climate
change. The following are the main findings
and conclusions found:

###### American Petroleum Institute (API)
API represents all segments of America's
natural gas and oil industry, which supports
more than 11 million U.S. jobs and is backed
by a growing grassroots movement of millions
of Americans. API's mission is to promote safety
across the industry globally and to influence
public policy in support of a strong, viable
U.S. oil and natural gas industry.

Since the publication, in March 2021,
of API's first **[Climate Action Framework,](https://www.api.org/climate)**
we acknowledge a more positive engagement
on climate policies and more alignment than
in the previous review. One of the main positive
**outcomes is the active support to cost-effective**

**policies and direct federal regulation to reduce**
**methane emissions across the supply chain,**
through engagement with the Environmental
Protection Agency. Reducing methane emissions
is a priority for our industry to address the risks
of climate change.

**From 2022, Repsol is represented in API's**
**Board Member of Directors so that we will be**
better positioned to support the organisation
in further developing key policy positions.

Repsol continues to maintain its classification as
"partially aligned" for this year, while it welcomes
the significant progress made, and it will continue
to evaluate and support further positive progress.

###### Oil Companies International
Marine Forum, (OCIMF)
OCIMF is an international voluntary association
of oil companies with an interest in shipment
and terminal operations for crude oil, oil
products, petrochemicals, and natural gas.

**Repsol is currently represented in the**
**organisation's technical and expert committees**
and has no representative in the Executive
Board. By working collaboratively to develop
tools and resources to help the marine industry
respond to ever-changing risks, OCIMF seeks
to continuously improve safety, security,
health, and environmental performance.

This is the first time we have included OCIMF
in our review.

Currently, OCIMF is finalising its positions
on climate-related policies, which means
that we have not yet been able to find evidence
of alignment with many of our climate positions.

While OCIMF expresses strong support
for global greenhouse gas (GHG) reductions
that will enable the maritime industry
to move toward a net zero carbon future,
we will continue to encourage OCIMF
to broaden its climate positions to promote
climate advocacy in the sector.

Repsol has a Sustainable Financing Committee in charge to select, review, evaluate and monitor the Green Eligible Projects and Transition Eligible Projects financed by Repsol's Use of Proceeds Financing Instruments, and to select, review and monitor the Key Performance Indicators (KPIs) and Calibration of Sustainability Performance Targets (SPTs) included at Repsol's Sustainability-Linked Financing Instruments, to verify their compliance with the commitments described under the Framework. The committee is chaired by the Financing Director, and includes, among others, the Sustainability Director, the Head of Transition Energy and Climate Change, the Head of Strategy on Sustainability and relevant representatives from the Business and Corporate Divisions. [...] The Sustainable Financing Committee has committed to select, review and monitor the Key Performance Indicators (KPIs) and Calibration of Sustainability Performance Targets (SPTs) set at this framework.

###### Update of Repsol's participation on industry associations

Repsol's climate policy positions

[Repsol's updated climate policy positions have](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2022/repsol-climate-policy-positions-2022.pdf)
been published on our website in July 2022

In an explicit commitment to transparency
and recognising investor interest in this matter,
Repsol has established five principles that define
our climate policy positions.

They represent the global framework of climate
**change and energy transition positions for**
Repsol's advocacy with different stakeholders,
from governments to international organisations,
and they are used to assess the alignment of the
industry associations to which Repsol belongs
with the company's positions.

Our positions will continue to evolve in line
with scientific evidence, multilateral agreements,
regulations, and other key drivers of global
progress to achieve net zero emissions by 2050.

###### 2022 Assesment

[In this assessment, we have reviewed](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2022/participation-in-associations-climate-review-update.pdf)
**32 initiatives and associations selected**
in accordance with the following criteria:

a) Links with the energy sector.

b) Regions or countries where Repsol has

significant business activities.

c) Relevance in relation to climate change matters.

Using publicly available information,
the associations were assessed to be aligned,
**partially aligned, or not aligned with our**
climate-related position.

**Aligned: the association expressly states**
its commitment to adhere to the objectives
established in the Paris Agreement and
its actions are consistent or not in conflict
with Repsol's climate policy positions.

**Partially aligned: the association has not defined**
a public position regarding the Paris Agreement
or Repsol has raised some concerns about its
position in relevant climate matters.

**Not aligned: the association has a public**
position that is contrary to or in significant
conflict with Repsol's climate policy positions
and/or the Paris Agreement

[Since the first assessment of Repsol's](https://www.repsol.com/content/dam/repsol-corporate/en_gb/sostenibilidad/reports/2019/assessing_repsol_participation_initiaves_associations_climate_change_tcm14-181638.pdf)
participation in industry initiatives
and associations, we have added
**new associations that fit with the selected**
criteria and eliminated those of a highly
technical scope, think tanks, and non-affiliate
relationships such as NGOs or investor
groups, as well as government initiatives
and committees.

As an overall conclusion, we found that most
of our memberships are aligned with Repsol's
climate positions. Out of the 32 associations
**reviewed, 30 are aligned and 2 partially aligned.**

We collaborate in these associations
and initiatives and encourage the development
of their lines of action in accordance with
our climate position, paying membership fees
and participating in working groups
and collaborative events they organise.

The associations identified as partially
**aligned in 2021 have been re-evaluated,**
and we have established an open
and constructive dialogue to encourage
greater involvement, collaboration, and
commitment in their actions against climate
change. The following are the main findings
and conclusions found:

###### American Petroleum Institute (API)
API represents all segments of America's
natural gas and oil industry, which supports
more than 11 million U.S. jobs and is backed
by a growing grassroots movement of millions
of Americans. API's mission is to promote safety
across the industry globally and to influence
public policy in support of a strong, viable
U.S. oil and natural gas industry.

Since the publication, in March 2021,
of API's first **[Climate Action Framework,](https://www.api.org/climate)**
we acknowledge a more positive engagement
on climate policies and more alignment than
in the previous review. One of the main positive
**outcomes is the active support to cost-effective**

**policies and direct federal regulation to reduce**
**methane emissions across the supply chain,**
through engagement with the Environmental
Protection Agency. Reducing methane emissions
is a priority for our industry to address the risks
of climate change.

**From 2022, Repsol is represented in API's**
**Board Member of Directors so that we will be**
better positioned to support the organisation
in further developing key policy positions.

Repsol continues to maintain its classification as
"partially aligned" for this year, while it welcomes
the significant progress made, and it will continue
to evaluate and support further positive progress.

###### Oil Companies International
Marine Forum, (OCIMF)
OCIMF is an international voluntary association
of oil companies with an interest in shipment
and terminal operations for crude oil, oil
products, petrochemicals, and natural gas.

**Repsol is currently represented in the**
**organisation's technical and expert committees**
and has no representative in the Executive
Board. By working collaboratively to develop
tools and resources to help the marine industry
respond to ever-changing risks, OCIMF seeks
to continuously improve safety, security,
health, and environmental performance.

This is the first time we have included OCIMF
in our review.

Currently, OCIMF is finalising its positions
on climate-related policies, which means
that we have not yet been able to find evidence
of alignment with many of our climate positions.

While OCIMF expresses strong support
for global greenhouse gas (GHG) reductions
that will enable the maritime industry
to move toward a net zero carbon future,
we will continue to encourage OCIMF
to broaden its climate positions to promote
climate advocacy in the sector.

Repsol's commitment is to achieve net zero emissions by 2050. We are decarbonizing traditional operations, generating renewable electricity, and producing renewable fuels to offer society decarbonized and affordable solutions for mobility, industry, and residential sectors. We strongly advocate for close collaboration between companies, industrial associations, and governments, to establish well-designed policy frameworks that enable a rapid and organized energy transition aligned with the goals set forth in the Paris Agreement. This means ensuring that our energy systems evolve swiftly while considering two crucial factors: affordability for consumers and the security of energy supply. Repsol has established five principles that define our climate policy positions. They represent the global framework of climate change and energy transition positions that is the basis for Repsol's advocacy with different stakeholders, from governments to international organizations. We also assess the alignment with these same principles of the industry associations to which Repsol belongs. We have recently revised the principles, and they will continue to evolve in consistency with scientific evidence, multilateral agreements, regulations, our own business transformation efforts, and other key drivers of global progress to achieve net zero emissions by 2050. We believe that our advocacy has a relevant role to play in supporting the ongoing energy transition towards a more sustainable future.

We acknowledge the increasing demand from our stakeholders for enhanced transparency regarding corporate lobbying activities, particularly in the context of climate change and the energy transition. Investor initiatives, such as the Climate Action 100+ Net Zero Company Benchmark and the Global Standard on Responsible Corporate Climate Lobbying, have emerged to promote greater transparency in climate-related lobbying efforts undertaken by companies and industry associations. [...] We have implemented an assessment approach that includes the following steps[1]: **1. Identify main initiatives and associations.** **2. Assess whether the associations' positions are consistent with both the** fulfilment of the goals of the Paris Agreement and our climate policy positions. **3. Act to address all cases of potential misalignment.** **4. Monitor and review lobbying activities and alignment with Repsol's climate** positions once a year, disclosing publicly the results of this assessment. [...] The internal assessment process is carried out with the participation of several corporate areas (Sustainability, Institutional Relations, and Investors Relations) as well as incumbent businesses and regional teams. [...] Following the identification process, all publicly available policy and advocacy information on the industry associations is collected and analyzed, including a review of their websites, position letters, and social media. The associations are then approached to request other relevant information regarding their alignment with both the goals of the Paris Agreement and Repsol's climate change policies. [...] Depending on the level of alignment, the company will take the necessary measures to bring the diverging climate positions and strategies closer together, considering the views and perspectives of each party: - This process is applied to all associations, including those classified as aligned, to address any potential differences that could arise in the future. - For aligned associations, we will maintain our engagement and collaborate constructively on policies related to climate change and the energy transition - For partially aligned associations, we will continue to engage in an open and constructive dialogue to promote energy transition policies that support the goal of the Paris Agreement. We will track alignment and will be transparent about where we find differences and always try to find opportunities to influence and collaborate. [...] We will terminate our membership in non-aligned associations. We will leave the possibility of resuming the relationship open in case our positions on climate change re-align in the future. [...] We will continue reviewing developments in associations policies on climate change, as well as our own positions to identify potential misalignments early, and we are committed to publishing an updated report each year.

As part of our steadfast commitment to the fight against climate change and the decarbonization of the economy, we've ensured that all the associations and initiatives in which we participate are aligned with the fulfillment of the goals set out in the Paris Agreement. [...] Assessing Repsol's participation in industry initiatives and associations: Climate Change [...] Sustainability Committee [...] Committed to transparency We've published an archive with our annual sustainability reports as well as reports on associations and initiatives with relevant information on our operations.

Moreover, every year we assess whether the Associations and Initiatives in which Repsol participates are aligned with the Paris goals and with our own climate change positioning. To this end, these Associations are classified into "Aligned", "Partially Aligned", or "Non-Aligned" depending on their express commitment to adhere to the goals established in the Paris Agreement and the consistency of their actions with Repsol's climate change strategy. The Company does not currently take part in any Non-Aligned association or initiative.

The company's governance bodies play a key role in deploying this strategy. The functions of the Sustainability Committee and the Audit and Control Committee include overseeing and steering the Group's policy, objectives and guidelines on sustainability and human rights, as well as reviewing and evaluating the controls for management systems and nonfinancial reporting. The existence and efficiency of these bodies enable the company to address the challenges that today's society demands of us. [...] Respect for human rights is a priority for Repsol in every country in which we operate, aligned with the strictest international standards and based on two fundamental pillars: - Commitment maintained at the top level of the company. - Outstanding performance in all operations. To achieve this excellence, Repsol performs human rights due diligence as the ideal model for managing internal processes and identifying, preventing and mitigating the impacts of the company's activities. Additionally, the grievance mechanisms in place help us to detect and remediate any violations of human rights and feed back into our due diligence processes.

Repsol has an ongoing engagement on environmental, social and governance (ESG) issues with our stakeholders, to learn first-hand their opinion on these matters and explain the Company's practices. Climate change is a key topic of this engagement strategy, as Repsol is committed to be a net zero emissions company in 2050 and the 21-25 strategy is strongly focused on energy transition. Methods of engagement include dedicated channels on the company's website, surveys, roadshows and workshops, dissemination campaigns, bulletins and advertising among others. The Integrated management report is another important means of engaging with all our stakeholders, accounting for the sustainability performance of the reporting year. At Repsol, we identify and prioritize our stakeholders and its expectations through materiality analysis that are annually carried out, involving all areas that interact with stakeholders and incorporating the results as key input into sustainability strategy. In 2021 we have updated our 2020 materiality analysis. The materiality analysis at Repsol is a process with 4 phases: 1. Stakeholder analysis and relations: the stakeholders (other agents in the value chain) that we consider are those included in our stakeholder map. We evaluate the channels and frequency of communication as well as their expectations for information regarding our management to ensure that the engagement process is adequate. We measure the success of the engagement consulting the management areas and groups on the effectiveness of the communication. The stakeholder map is structured into 8 stakeholder groups (1.Shareholders, investors and financial institutions, 2.Employees, 3. Society, 4.Partners, competitors and business associations, 5.Public institutions and organizations, 6.Media, 7. Suppliers and contractors and 8.Customers). Information on engagement with suppliers and customers is given under question C.12.1a and b). 2. Identification of potentially material topics: 34 sustainability-related topics with the were identified, grouped into 10 pillars. 3. Prioritization of material topics: topics are prioritized both applying the double materiality concept. The methodology has been based on interviews, surveys and the analysis of documents and an artificial intelligent tool. In 2021, more than 2,700 interviews and surveys were conducted, with a participation rate of 40%. 4. Construction of materiality matrixes: materiality matrixes are calculated and thresholds are designated in order to determine the material topics. In 2021, 21 material topics were identified. A global company-wide matrix and 8 specific stakeholder matrices were obtained. 5. Validation & communication of results The 2020 results of the materiality analysis show that climate change issues ("GHG emissions and energy transition strategies" and "Energy and climate policies and regulation") are the highest ranked in the materiality matrix, being considered of critical importance both for Repsol and for its stakeholders. The findings of the materiality analysis are embedded in the Sustainability Strategy and deployed downstream through the Global Plan and Local Sustainability Plans. The actions under the plans, locally and globally, are aimed at improving performance and minimizing the impact of identified sustainability risks. This enables the Company to think strategically and take decisions to evolve the business model to ensure economic, environmental and social sustainability. Case study: Shareholders, investors and financial institutions are a key stakeholder group for Repsol. Repsol engages in continuous communication and dialogue with them and in different ways: roadshows, events, calls, reports… The CEO of the Company directs and leads senior management roadshows with socially responsible investors to respond to their requests for information on climate change. At year-end 2021, ESG investors accounted for 40% of shares held by institutional shareholders (vs 32% in 2020). The increase is a measure of success of our ESG communication efforts with investors. Repsol published in 2021 the 7th ESG engagement report where we summarize the communication activities that we have held with our investors during 2020 and the first half of 2021. The publication of an annual report of interaction with ESG investors is further proof of our commitment to transparency in communication with our investors. Repsol held in October 2021 the "Low Carbon Day", an event led by our CEO and dedicated to explaining and detailing its energy transition to analysts and investors. Our CEO announced more ambitious targets that will accelerate its energy transition to become a net zero emissions company by 2050: an increase in the company's renewable generation and emission reduction targets, as well as an increase in investments in low-carbon solutions to accelerate the transformation until 2030.

In the European Union and the United States, we also report on costs related to lobbying activities in accordance with the requirements and guidelines set out in the EU Transparency Register and the US Lobbying Disclosure Act. All information reported by the company is public. [...] Regarding the partially aligned associations, we have established an open and constructive dialogue to encourage greater involvement, collaboration and commitment in their actions against climate change. [...] In 2022, we will once again review and update our participation in industry associations and initiatives.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]At Repsol, we share society's concern about the ef­ects that human activities cause on the climate and we are firmly committed to an energy transition towards a low-emission future.
We have set ourselves ambitious targets in the fight against climate change as we are convinced that only by tackling the great challenges, we can turn them into opportunities. In December 2019, Repsol was the first company in its sector to announce its commitment to become a net zero emissions company by 2050. It aims to contribute to the goal set by the Paris Agreement of limiting the increase in the global average temperature of the planet to well below 2 degrees Celsius above pre-industrial levels by the end of the century, and if possible, not exceed 1.5 degrees.
In November 2020, Repsol unveiled its new Strategic Plan which is committed to operational excellence, innovation and investment in new low-carbon energy solutions to become a decarbonised company.
With the technological advances now foreseeable, we anticipate that we can achieve at least 80% net emissions reductions by 2050 and commit to applying the best technologies to raise this figure. If that is not enough, we will o­set emissions through natural climate solutions to achieve net zero emissions by 2050.
All of our engagement activities are aimed at achieving these objectives. At Repsol we have an internal area that is responsible for coordinating all of the company's engagement initiatives, whether they are carried out directly or through associations.
In addition, since 2020, we have been updating a report every year that analyzes the associations we are part of and assesses their degree of alignment with our strategy.
Since the publication of this report, we have added new associations and revised those included in the initial list, eliminating groups of a highly technical scope, think tanks, and non-aliate relationships such as those of NGOs or investor groups, as well as government initiatives and committees. We collaborate in these associations and initiatives and encourage the development of their lines of action by paying membership fees and supporting and participating in the working groups and events they organize.
In the European Union and the United States, we also report on costs related to lobbying activities in accordance with the requirements and guidelines set out in the EU Transparency Register and the US Lobbying Disclosure Act. All information reported by the company is public.