Ecopetrol SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Ecopetrol SA provides a highly detailed picture of its climate-policy lobbying. It names a wide range of specific Colombian measures it has engaged on, including the CONPES “Energy Transition Policy,” the “Integral Climate Change Plan of the Mines and Energy sector” (Resolution 40807), draft decrees amending the carbon-tax provisions of Decree 1076/2015 and regulating Carbon Capture, Use and Storage under Law 2099/2021, the design of the national cap-and-trade system (PNCTE), Resolution 40066/2022 on methane, the 2169 Law of 2021, ANH’s Open Area Nomination Process – PANA, and a draft resolution on verification of GHG-mitigation initiatives, leaving little doubt about which policies it seeks to influence. For each of these files the company sets out the methods it used and whom it approached: it “participated in technical round tables for consultation,” joined “construction workshops,” “provided corporate information for the sectorial baseline,” lodged comments in a “participative regulatory process,” and engaged directly with identified authorities such as the Ministry of Mines and Energy, the Ministry of Environment and Sustainable Development and the National Hydrocarbons Agency. Ecopetrol is equally explicit about what it wants from these engagements. It backs the Energy Transition Policy “without exceptions” to drive national energy transformation, supports lowering the carbon-tax neutralisation limit while safeguarding “reduction projects funding” and “carbon neutrality declarations,” presses for “the promotion, implementation and development of CCUS technologies” with robust measurement and verification rules, advocates adding a “carbon management chapter” with direct- and indirect-emission requirements to the ANH process, and calls for clear criteria for validation and verification of mitigation initiatives. By specifying the policies, the mechanisms and the concrete outcomes it pursues, the company demonstrates a comprehensive level of transparency around its climate lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Hitachi discloses a formal mechanism for aligning at least some of its climate-related advocacy with corporate climate goals, but the description remains limited in scope and detail. The company states that The written opinion submitted by Hitachi High-Tech to the business association is submitted after confirming the direction and consistency of Hitachis long-term goals We are checking the consistency of the written Hitachis opinions submitted to trade associations through the participation of Sustainability Committee with exchange of opinions, indicating an articulated process to review indirect lobbying statements before they are filed. Oversight responsibility is placed with a senior body: Hitachi reports important matters to the Sustainability Committee chaired by Hitachis CEO, and Hitachi High-Tech participates in and exchanges opinions with Hitachis Sustainability Committee, and more broadly, Important items related to environmental initiatives in the Hitachi Group are deliberated by the Executive Sustainability Committee, chaired by the executive chairman and CEO of Hitachi, Ltd. These quotes demonstrate that a named committee chaired by the CEO reviews climate-related engagement activities. Hitachi also makes a public commitment that its advocacy will be Paris-aligned, stating Yes when asked whether it has a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement. However, the disclosures do not describe a systematic review of direct lobbying undertaken by Hitachis own government-affairs staff, nor do they provide a public audit of trade-association alignment or detail how inconsistencies are resolved; for example, the company notes only that We will also seek ways to address potential inconsistencies without outlining criteria, timelines or consequences.	1