E.ON SE

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	E.ON SE provides a highly detailed and specific picture of its climate-related lobbying. It names numerous individual policies it has tried to influence – including the EU “Fit for 55” legislative package, the “Clean Energy for All Europeans” winter package, reforms to the EU Emissions Trading System (EU-ETS), the German Fuel Emissions Trading Act (BEHG) and proposals for an EU-wide carbon tax – as well as its participation in the Carbon Pricing Leadership Coalition and the EU-ETS2 debate. The company also describes a wide range of lobbying channels and the bodies it seeks to influence: direct speeches and talks by the CEO with EU, federal and state politicians, public addresses such as the CEO’s “Energy in Europe” speech in Berlin, joint declarations with other companies and NGOs, membership of sector associations such as Eurelectric and WindEurope, its role in the “Friends of the ETS” coalition advising the European Commission, Council and Parliament, and its work in the cross-sector CEO Alliance that delivers recommendations to the European Commission. Finally, E.ON sets out the concrete outcomes it is pursuing, calling for “a strengthening of the EU-ETS” including the withdrawal of hundreds of millions of EU allowances and the introduction of a minimum carbon price, advocating “sending a strong carbon pricing signal,” backing an EU-wide efficiency target of at least 30 % by 2030 with binding national targets, and pressing for carbon taxes or price floors to decarbonise mobility, buildings and other sectors. By clearly linking the specific policies, the methods of engagement and the precise legislative changes it wants, the company demonstrates a comprehensive level of transparency on its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	E.ON SE demonstrates a comprehensive climate lobbying governance process that ensures alignment with its climate-related goals and promotes transparency. The company has published a "Climate Advocacy and Associations Report," which evaluates the alignment of its climate-related lobbying activities, covering 56 memberships relevant to climate advocacy, including positions on the Paris Agreement, the Fit-for-55 package, sustainable finance, and carbon pricing. E.ON explicitly states that it "analysed whether the initiatives we take part in support our perspectives" and categorized them as aligned, partially aligned, or misaligned. The company commits to engaging in dialogue with misaligned associations to address non-conformance and, if necessary, "challenge the continuation of those memberships." This indicates active alignment of both direct and indirect lobbying activities. Furthermore, E.ON discloses that its policy-related activities are overseen by appropriate functions, ensuring that "those responsiblefrom the administrative level to the Supervisory Boardare informed about our stakeholders interests." The company also plans to "regularly publish an updated version" of its Climate Advocacy and Associations Report, demonstrating a commitment to continuous monitoring and transparency. This robust governance framework is further supported by its alignment with international climate goals, such as the Paris Agreement, and its proactive stance in addressing misalignments with trade associations.	4