BP PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	BP discloses climate-policy advocacy in considerable depth. It identifies a wide array of concrete measures it has engaged on, including the US “Inflation Reduction Act”, the “EPA methane regulations”, Washington State’s “Climate Commitment Act”, Australia’s “Safeguard Mechanism” reforms, the EU “Fit-for-55” and “CBAM” proposals, the UK “Energy Act 2023”, Illinois “Senate Bill 1289” on CCS, and many other named consultations and rulemakings across the US, EU, UK, Canada, Australia, New Zealand and Korea. The company also explains how it lobbies. Examples include formal comment letters filed through Regulations.gov to the IRS and CEQ, oral and written testimony before state legislative committees, “face-to-face meetings with members of the Scottish Parliament, officials, ministers and special advisors”, submissions to European Commission public consultations, responses to Australian Senate inquiries, and public coalition letters to Congressional leadership. Targets are consistently specified—e.g., the US EPA, UK Government departments, the EU Commission, the Illinois and Indiana legislatures, the Korean MOTIE, and the Australian DCCEEW—making the avenues and audiences for influence clear. BP is equally explicit about the outcomes it seeks. It urges the EPA to “harness the power of innovative technology in leak detection and monitoring” and adopt a “flexible continuous monitoring framework”; asks the IRS to let “cleaning and conditioning equipment” qualify for biogas investment tax credits; proposes extending Australia’s Hydrogen Production Tax Incentive beyond 2040; supports an EU 2040 climate-neutrality target backed by an expanded ETS and fixed carbon-removal quotas; and backs Virginia and Pennsylvania joining the Regional Greenhouse Gas Initiative. It calls for clear CCS permitting rules in Illinois, a Low Carbon Fuel Standard in Australia, and carbon prices “at least $100 per tonne” to accelerate renewables. These detailed, measurable policy objectives demonstrate that BP not only describes what it supports but specifies the legal or regulatory changes it wants enacted. Taken together, the breadth of named policies, the precise description of engagement channels and targets, and the articulation of concrete legislative and regulatory outcomes represent a very high level of transparency in BP’s disclosure of its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	BP discloses a detailed and recurring governance system that addresses both its own advocacy and its memberships in external bodies, supported by public, climate-specific reviews and clear lines of accountability. The company states that, after an in-depth review examining the alignment of the climate-related policies and activities of trade associations with BPs positions, it has already exited three associations and identified a further five organizations with which it is only partially aligned, demonstrating an active mechanism for correcting misalignment. Those reviews are publicly released for example, In April 2022 we published our second detailed trade associations review and include a third-party check: We engaged third-party consultants, Environmental Resources Management (ERM) to do the initial review, using a process that ERM consider to be rigorous, consistent, objective and fair. Oversight is explicitly allocated: The board-level safety and sustainability committee (S&SC) oversees effective implementation of the sustainability frame, while management oversight of sustainability is embedded through our executive-level group sustainability committee chaired by our executive vice president, strategy, sustainability & ventures, and Our main public policy positions are subject to endorsement by the sustainability forum and regional policy forums. Direct lobbying is governed through Aim 6 whereby any corporate advertising will be to advocate for progressive climate policy and a policy team that monitors policy trends and leads the definition of policy positions in line with bps strategy and sustainability aims, ensuring advocacy is aligned with the net-zero strategy. For indirect lobbying the company periodically assess[es] the alignment of key associations with our position on climate our priority is to influence within trade associations, but we may publicly dissent or resign our membership if there is material misalignment, a commitment it has already executed by leaving AFPM, WSPA and WEA. The process includes regular reporting to the board BP will actively monitor its memberships and will provide periodic updates, internally to the board of directors and sets a schedule for future reviews BP plans to undertake another review in around two years time. While the disclosures focus more heavily on trade associations than on a formal audit of every instance of direct lobbying, the combination of board-approved policy positions, executive oversight, third-partysupported audits, and a demonstrated willingness to disengage from misaligned bodies indicates transparent and comprehensive governance of both direct and indirect climate-related lobbying activities.	4