Thyssenkrupp AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Thyssenkrupp AG provides a highly detailed picture of its climate-policy lobbying. It names a broad suite of concrete measures it engages on, including the EU “Fit for 55” legislative package, the “Ecodesign Directive (Directive 2009/125/EC),” the “EU Emissions Trading System and Carbon Border Adjustment Mechanism,” the “EU hydrogen and decarbonised gas package,” reform of “electricity market design,” Germany’s national and state-level hydrogen strategies, and the German “Climate Protection Act 2021.” The company is equally explicit about how and where it lobbies. It describes engaging “both directly and through its trade associations by providing input to and feedback on the legislative proposals of the European Commission,” taking part in stakeholder meetings during the Ecodesign preparatory study, maintaining “a continuous dialogue with political decision-makers,” participating in UN climate conferences, and advancing its positions through organisations such as Hydrogen Europe, EUROFER, BDI and BIAC. Specific targets are identified, notably the European Commission and the German federal government, as well as state-level bodies in North-Rhine-Westphalia. Thyssenkrupp also sets out the outcomes it seeks. It supports “free allocations [to] be kept at reasonable levels … until 2030,” advocates “a transition period with flexibility in the implementation of the additionality and correlation criteria for green hydrogen,” opposes post-2030 “unbundling of gas and hydrogen distribution activities,” calls for “facilitating access to long-term power purchase agreements” and “investment support in the form of two-sided contracts for difference,” and backs “Carbon Contracts for Difference” to spur climate-neutral steel. These positions show clearly defined policy changes, timelines and rationales. Taken together, the company demonstrates a comprehensive level of transparency around the specific climate policies it lobbies, the mechanisms and targets of that lobbying, and the concrete outcomes it seeks.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Thyssenkrupp AG demonstrates some governance around climate-related lobbying at the Business Unit level, notably through TK Elevators approach of communicating our Science Based Targets top-down to the Business Units, where each BU assigns a BU Coordinator who monitors the progress of our climate targets and KPIs, and coordinates all engagement initiatives and other local activities in line with the global targets, which it says ensures all our engagement activities are consistent with our overall climate change strategy. This structure covers both direct lobbyingillustrated by engagement with the European Commission on the Ecodesign Directiveand indirect activity through trade associations under the coordination of the BU Coordinator. The company also makes a public commitment to the international targets of the Paris Climate Agreement, affirming that our direct and indirect engagement is consistently in line with our commitment to the Paris Climate Agreement. However, we found no evidence of a dedicated climate-lobbying audit or report, no disclosure of a specific board committee or named senior executive responsible for overseeing climate lobbying alignment,or specific processes to monitor or enforce alignment of its lobbying activities with its climate objectives across the broader organization.	2