MOL Hungarian Oil & Gas PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	MOL Hungarian Oil & Gas PLC provides an exceptionally detailed picture of its climate-policy lobbying. It names a wide range of concrete initiatives it has worked on – from several elements of the EU “Fit for 55” package such as the EU Emissions Trading System, Carbon Border Adjustment Mechanism, Renewable Energy Directive, Energy Efficiency Directive, Alternative Fuel Infrastructure Directive and ReFuelEU Aviation, to national instruments including the “Hungarian energy efficiency law and obligation scheme” and Croatian policies on “CCS and CCUS.” The company also sets out how it tries to influence those measures, citing “participation in public consultations, national stakeholder events, and in some cases organised direct meetings with national decision makers,” all coordinated from its Budapest headquarters and supported by its listing in the EU Transparency Register; the intended targets – “EU and Member State policymakers” and “national decision makers” in Croatia – are clearly identified. Finally, MOL is explicit about the changes it seeks: it advocates “creating regulatory conditions for hydrogen uptake,” “increasing energy savings from all technologies,” the “gradual uptake of sustainable aviation fuels,” ensuring CCS ambition “is in line with our strategy,” and widening energy-efficiency obligations so that “savings can be achieved in the most efficient way,” all while safeguarding Central and Eastern European industrial competitiveness and aligning with the Paris Agreement. Taken together, these disclosures demonstrate a comprehensive and transparent account of the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	MOL Hungarian Oil & Gas PLC has established a basic framework for aligning its policy engagement with its climate strategy, noting that “MOL Group’s strategy and organizational development departments and its regulatory & public affairs department both belong to the Group Strategic Operations and Corporate Development organization,” which “enables direct lines to make sure that strategy is reflected in engagement activities,” and stating that “all relevant business departments are consulted to make sure that engagement is in line with MOL Group’s strategic directions.” The company also affirms a public commitment to align its engagement activities with the Paris Agreement, answering “Yes” to having a position statement to that effect. However, we found no evidence of a specific individual or board committee overseeing climate lobbying alignment, no description of how indirect lobbying through trade or industry associations is governed, and no dedicated policy or detailed review process for monitoring lobbying activities against its climate commitments.	2