Turk Hava Yollari AO – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Turkish Airlines signals a structured – but still limited – approach to governing climate-related advocacy. The company explains that its Sustainability Committee, “chaired by the CEO who is the General Manager of the company and a Board member,” is tasked with “evaluating the issues that will affect the activities of the company, which are addressed in the national and international committees, technical teams and working groups of which the Incorporation is a member,” and that decisions from this committee are “reported directly to the Board by the CEO… and submitted to the approval of the Board at regular Board meetings.” This shows a named senior body with board-level escalation reviewing external policy forums in which the airline participates. In response to questions on external engagement, the company adds that “through the AIRE organization’s Sustainability Task Force, we evaluate sustainability regulations and solutions and communicate them to relevant authorities,” and that it has “process(es)… to ensure that your external engagement activities are consistent with your environmental commitments and/or transition plan,” noting it “align[s] our business strategies with IATA's climate change targets.” Together these statements indicate there is a mechanism to check that at least some direct and indirect advocacy matches the firm’s climate strategy. Nonetheless, the disclosures remain high-level: they do not describe how direct lobbying positions are reviewed, give no criteria for judging or correcting misalignment within trade associations, and do not reference any publicly released lobbying-alignment audit or review, so transparency and coverage appear moderate rather than comprehensive. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Turkish Airlines signals a structured – but still limited – approach to governing climate-related advocacy. The company explains that its Sustainability Committee, “chaired by the CEO who is the General Manager of the company and a Board member,” is tasked with “evaluating the issues that will affect the activities of the company, which are addressed in the national and international committees, technical teams and working groups of which the Incorporation is a member,” and that decisions from this committee are “reported directly to the Board by the CEO… and submitted to the approval of the Board at regular Board meetings.” This shows a named senior body with board-level escalation reviewing external policy forums in which the airline participates. In response to questions on external engagement, the company adds that “through the AIRE organization’s Sustainability Task Force, we evaluate sustainability regulations and solutions and communicate them to relevant authorities,” and that it has “process(es)… to ensure that your external engagement activities are consistent with your environmental commitments and/or transition plan,” noting it “align[s] our business strategies with IATA's climate change targets.” Together these statements indicate there is a mechanism to check that at least some direct and indirect advocacy matches the firm’s climate strategy. Nonetheless, the disclosures remain high-level: they do not describe how direct lobbying positions are reviewed, give no criteria for judging or correcting misalignment within trade associations, and do not reference any publicly released lobbying-alignment audit or review, so transparency and coverage appear moderate rather than comprehensive.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Turkish Airlines provides a high level of transparency around its climate-policy lobbying. It names several concrete measures it engages on, including the draft “Sustainable Aviation Fuel (SAF) Regulation” issued by Türkiye’s Directorate General of Civil Aviation (DGCA), the DGCA’s 22 March 2022 “Regulation on the Monitoring of GHG Emissions Originating from Aviation Activities,” and international regimes such as the EU, UK and Switzerland Emissions Trading Systems as well as ICAO’s CORSIA scheme, demonstrating clear disclosure of the specific policies it seeks to influence. The company also explains how it lobbies: it sends written comments and attends stakeholder meetings with the DGCA, participates in DGCA-led pilot projects such as the Data Management System, registers on the EU Transparency Register, and works through industry bodies like IATA and AIRE, thereby identifying both the mechanisms (letters, workshops, committee work) and the targets (DGCA, T.C. Ministry of Environment, TSE, TURKAK, EU bodies). On desired outcomes, Turkish Airlines states that it wants SAF blending mandates to be implemented in a way that supports a “long-term guaranteed purchase” framework, seeks improvements to the DGCA MRV system, and intends that “emissions that exceed the determined base year emissions amount will be offset,” linking these objectives to its 2050 net-zero goal. While some ambitions are broad, the company nonetheless discloses at least two concrete policy outcomes it is pursuing, giving stakeholders a clear picture of how its lobbying aligns with its climate strategy. Together, these elements reflect strong overall transparency on its climate-related lobbying activities.	B