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| Overall Assessment |
Comment |
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| Comprehensive |
Shell PLC provides a highly detailed picture of its climate-policy advocacy. It names multiple identifiable measures it has engaged on, including the EU’s Fit for 55 package, the updated EU Emissions Trading System, the US Inflation Reduction Act, “EU CO2 emission performance standards for cars and vans,” the “ReFuelEU Aviation Regulation,” SEC climate-risk disclosure rules, national emissions-trading schemes in Brazil and China, reforms to Australia’s Safeguard Mechanism and Texas draft CCUS legislation, among many others. Shell also explains how it lobbies and who it targets. Disclosures describe submissions to European Commission consultations, testimony to the “US Senate Committee on Energy and Natural Resources,” letters to the UK Government on the oil and gas “climate-compatibility checkpoint,” recommendations “in our submission to the SEC,” and direct engagement with bodies such as the Texas Railroad Commission; the company adds that it “advocate[s] directly to governments and international organisations and through industry associations and coalitions,” listing the specific associations and coalitions it uses. Finally, Shell is explicit about the concrete outcomes it pursues: it backs “a direct price on carbon emissions,” seeks “a more ambitious sustainable aviation fuel blending mandate of 10 % by 2030,” supports “binding targets to reach economy-wide net-zero emissions by 2050,” calls for phasing out free allocation under the EU ETS alongside a robust CBAM, urges the UK to bring forward the ICE phase-out to 2030, and presses for rules to “end routine flaring by 2025” and for “expedited and ambitious methane regulation.” By combining specific policies, clearly described lobbying channels and named policymaking targets, and well-defined legislative outcomes, Shell demonstrates a comprehensive level of transparency around its climate-related lobbying activities.
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Shell publicly discloses an extensive climate-lobbying governance system that combines board-level oversight, defined internal controls and a published alignment review. The company states that "Shell senior executives approve our advocacy priorities each year" and that the Safety, Environment and Sustainability Committee (SESCo) "assists the Board in reviewing the practices and performance of the Shell Group including Climate Change," demonstrating clear assignment of responsibility for lobbying alignment. Its governance rules are embedded in the Shell Control Framework and operationalised through "our principles for participation in industry associations [which] govern how we manage our relationships on climate-related policy" and "have been incorporated in the Shell Control Framework, which sets the requirements for how all Shell entities operate." Shell provides a dedicated, publicly available audit: "This is Shells first Climate and Energy Transition Lobbying Report, which gives details of our lobbying in 2022 and includes our review of industry associations this is the fifth year that we have reviewed our memberships," covering 39 associations and classifying each as aligned, some misalignment or material misalignment. The company shows active management of indirect lobbying by committing that "I am writing to the 10 industry associations where we have found some misalignment to call for changes to some of their positions" and by putting specific demands on IGU and other bodies while pledging to "continue to track alignment and will be transparent about where we find differences." Direct lobbying is similarly governed: "Our global climate and energy transition policy positions serve as a general global framework for our advocacy we prioritise and adapt these positions at an international and country level," and Shell plans to "publish information about our direct and indirect climate and energy transition lobbying in some additional countries." The disclosure therefore includes a policy, a recurring review mechanism, corrective engagement (and potential escalation), and named board-level oversight, indicating comprehensive and transparent governance of both direct and indirect climate-related lobbying. Remaining gaps are minorfor example, the company notes it "plan[s] to publish our next update in 2022" and to expand country coverage, suggesting the process for direct lobbying transparency is still evolvingbut overall the evidence indicates a thorough, board-supervised system for ensuring lobbying alignment with its climate strategy.
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4
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