AP Moller - Maersk A/S

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	A.P. Moller-Maersk provides an extensive and detailed picture of its climate-policy lobbying. It names multiple identifiable measures it is working on, including the EU Emissions Trading System, the FuelEU Maritime Regulation within the EU “Fit-for-55” package, the International Maritime Organization’s GHG Strategy and related MEPC discussions, the Clydebank Declaration for green shipping corridors, and U.S. initiatives such as the Inflation Reduction Act and Clean Shipping Act. The company also explains how it tries to influence these rules, citing direct “bilateral meetings”, “discussions in public fora” and participation in technical working groups, alongside indirect advocacy through trade bodies like the World Shipping Council, Danish Shipping and the Getting to Zero Coalition, and it explicitly identifies its targets as “EU regulators”, “EU Member States” and “IMO Member States”. Finally, Maersk is explicit about the concrete outcomes it seeks: it “urges the IMO to adopt a target of net-zero emissions in 2050,” calls for “a global carbon price of USD 150 per ton CO2e”, wants the EU ETS to “include all relevant greenhouse gases and be based on a life-cycle analysis”, and supports an “end date for new building of fossil-fuel-only vessels” together with incentives for renewable fuels of non-biological origin. By clearly stating the policies, the channels of influence and the specific regulatory changes it is pursuing, the company demonstrates a very high level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	AP Moller Maersk describes its approach to align policy engagement with its climate strategy by confirming that senior company executives, responsible for our climate change strategy, discuss and decide engagement activities at the strategic level, including setting objectives, with frequent updates, exchanges and participation ensuring continuing alignment. The company commits that our climate policy outreach is conducted in line with the goals of the Paris Agreement and that we review our membership status once a year to ensure that our own policy engagement, as well as the trade associations in which we are members lobby in alignment with the goals of the Paris Agreement of 1.5 degrees Celsius. Action against this pledge was shown by its 2022 leaving of the International Chamber of Shipping (ICS), due largely to concerns over its climate lobbying. It also pledges to actively advocate for these associations to adopt Paris-aligned lobbying positions. This framework covers both direct engagement and indirect lobbying through membership in trade bodies and includes an annual review process. However, Maersk does not publish a dedicated climate-lobbying alignment report or audit, nor does it specify a named individual, formal body, or committee explicitly tasked with overseeing the lobbying review.	3