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| Overall Assessment |
Comment |
Score |
| Comprehensive |
TotalEnergies provides an exceptionally detailed picture of its climate-policy advocacy. It names multiple, identifiable measures it has engaged on, including EU files such as the revision of the Renewable Energy Directive, the EU ETS Innovation Fund delegated act, the Carbon Border Adjustment Mechanism and the broader “Fit-for-55” package, national proposals such as France’s Renewable Energy Acceleration Bill, and U.S. methane rules where, as it notes, "In November 2019, TotalEnergies wrote to the US-EPA … to oppose the projected lowering of regulatory requirements on methane emission control in the oil and gas industry." The company is equally explicit about how it lobbies and whom it targets: it cites written submissions and public-consultation responses to the European Commission, letters to U.S. regulators, participation in Senate hearings, direct input to the French Government’s Water Plan, and indirect work through associations like FuelsEurope and the Climate Leadership Council, with the key interlocutors – the European Commission, US-EPA, French ministries and other national authorities – all identified. Finally, TotalEnergies spells out the concrete outcomes it is pursuing: amendments to Innovation Fund rules (lowering the small-project CAPEX threshold to €15 m and broadening eligibility to grids and CO₂ transport), simplification of permitting to “accelerate the deployment of self-consumption solar installations”, formal adoption of a Carbon Border Adjustment Mechanism, preservation and tightening of U.S. methane standards, and elimination of routine flaring by 2030, among others. This combination of clearly named policies, transparent description of lobbying channels and targets, and specific, measurable policy objectives demonstrates a comprehensive level of disclosure on the company’s climate lobbying activities.
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4
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| Overall Assessment |
Comment |
Score |
| Strong |
TotalEnergies discloses a structured process for managing the climate-alignment of its external advocacy, centred on an internal Advocacy Directive that applies to all lobbying activities and sets six climate principles against which positions are tested. The company states that "since 2019, TotalEnergies has conducted an annual assessment of the climate-related public positions of the main professional associations of which it is a member" and that the review is now carried out "every two years [with] a partial review in the intervening years", demonstrating a recurring monitoring mechanism. The results are acted upon: after two successive findings that the American Petroleum Institute was only partially aligned, the company "announced its decision not to renew its membership" and likewise "withdrawn from AFPM and CAPP", showing it takes corrective action when misalignment persists. These assessments use the six principles covering Scientific position, The Paris Agreement, Carbon pricing, The development of renewable energies, The role of natural gas and Carbon offsetting, and the outcomes are publicly reported, which indicates meaningful governance of indirect lobbying. The disclosures also confirm that the same directive governs all advocacy efforts, implying coverage of direct lobbying, and the commitment that TotalEnergies refuses to intervene in the functioning or financing of the political life sits alongside the climate criteria, but no detail is given on how direct lobbying is formally reviewed against the six principles. Although Patrick Pouyann, Chairman and CEO, publicly endorses the alignment process we are committed to ensuring that the industry associations of which we are a member adopt positions and messages that are aligned with those of the Group in the fight against climate change the company does not disclose a designated board committee, named executive, or other formal body that oversees or signs off the climate-lobbying assessments, nor does it describe an internal lobbying audit or third-party review. Consequently, while the policy framework and evidence of action towards trade associations indicate solid governance, the absence of an explicit oversight structure and limited disclosure on direct-lobbying monitoring leave some gaps in transparency and assurance.
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3
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