UPM-Kymmene Oyj

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	UPM-Kymmene provides an unusually complete picture of its climate-policy lobbying. It names a wide range of identifiable measures it has worked on, including the “EU Taxonomy”, the revision of the “EU Emission Trading Scheme”, the “Fit for 55 proposal”, “REDIII”, the “ReFuel Aviation regulation”, the “LULUCF regulation”, the EU energy-efficiency directive, and the EU Commission’s ILUC proposal, as well as consultations on state-aid rules for energy-intensive industries. The company is equally explicit about how and where it seeks to influence these files: it “liaises directly with member state governments, members of the European parliament, and the Commission”, “responds to consultations”, comments on draft regulations, and works indirectly through national trade associations and coalitions such as CEPI and the Leaders of Sustainable Biofuels, all of which are listed alongside its EU transparency-register (861194311863-31) and German Lobbyregister entries. Finally, UPM spells out concrete objectives, for example it calls for “a stronger mandate for advanced biofuels within the REDIII”, wants “an advanced biofuels specific mandate within the ReFuel Aviation regulation”, seeks “coherence, transparency and clarity of the taxonomy criteria”, urges “limitations to the future use of 1G biofuels”, and asks that “early actions are recognised when new goals for efficiency are set”. By clearly linking each engagement to specific legislative texts, detailing the channels and targets of influence, and articulating the precise policy changes it supports or opposes, the company demonstrates a comprehensive level of transparency about its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	UPM-Kymmene Oyj has implemented a defined governance framework for its lobbying activities, with UPM Public Affairs led by the Vice President, Public Affairs. He reports to the Executive Vice President of Marketing, Sustainability and Communications, who is a member of the Group Executive Team, and supplemented by topic specific steering groups where our advocacy activities are steered, and these topics are reviewed in the Group Executive Team regularly, illustrating clear ownership and recurring oversight of its direct advocacy. The company also addresses indirect engagement by confirming that UPM is a member of various joint industry, sustainability and trade associations and networks. This is one way of influencing and monitoring the policies for being aligned with our strategy and climate pledge, and stating that UPMs engagement in trade associations and policy-related activities is globally based on this strategy, which ensures that all engagement is consistent with the overall climate change strategy, which indicates systematic alignment with its climate objectives. However, it has only disclosed its climate lobbying consistency with one trade association, the Confederation of European Paper Industries (CEPI), and it is not clear it has a process to address climate lobbying misalignments. It has also not disclosed a dedicated audit or public report explicitly evaluating the alignment of its climate-related lobbying efforts or any third-party review of its lobbying governance.	2