Siemens Energy AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Siemens Energy offers a highly transparent picture of its climate-policy lobbying. It names a wide array of concrete pieces of legislation it engages on – for example the revisions of the Energy Taxation Directive, Renewable Energy Directive II and III, TEN-E Regulation, EU Emissions Trading System, F-Gas Regulation, ReFuelEU Aviation, the EU Taxonomy Delegated Act, the Energy Efficiency Directive and many others – specifying the policy title, the stage of the legislative process and the geographic scope. The company also describes in detail how it seeks to influence those files, citing multiple routes such as “participating in public consultations by the European Commission”, submitting position papers, holding “bilateral talks with decision-makers at EU level”, and working “individually as well as via trade associations”; it identifies clear targets including the European Commission (DG CLIMA, DG TAXUD, DG MOVE, etc.), the European Parliament, Member-State governments and the European Chemicals Agency. Finally, Siemens Energy sets out the concrete outcomes it pursues: it advocates “to strengthen the CO2 link in energy taxation and allow Member States to exempt carbon-neutral fuels”, calls for “ambitious quotas for e-fuels in transport”, seeks “regulatory eligibility for green hydrogen” and a “differentiated phase-out for SF6 in high-voltage equipment”, asks for a “voluntary crediting system for renewable fuels” in vehicle CO2 standards, and supports carbon contracts for difference and a minimum CO2 price within the EU ETS, among many other specific positions. By coupling these detailed policy goals with clear descriptions of both the mechanisms and the targets of its lobbying, the company demonstrates a comprehensive level of transparency around its climate-related advocacy activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Siemens Energy AG has established a centralized Government Affairs function to align its climate-related policy advocacy, with the Global Government Affairs team reporting directly to the CEO to ensure "high visibility and accountability of the overall policy alignment on all climate and energy related issues worldwide." Direct lobbying activities are managed through processes where "any policy outreach on a country level is coordinated and supervised by the Global Government Affairs team, and, with regular reporting to the CEO," and climate issues are synchronized through "close coordination between the Government Affairs department and the Sustainability Office" to maintain consistency in strategy and communication. The Government Affairs department further "collaborates closely with the Divisions ... via the regularly established calls/exchanges with Strategy Departments of different Divisions," organizing workshops and scheduling regular alignment calls across regions. The company also confirms "Yes" when asked if it publicly commits its engagement to the goals of the Paris Agreement. However, we found no evidence of formal mechanisms for overseeing its indirect lobbying through trade or industry associations, nor of an independent audit or third-party review of its climate lobbying activities, which limits transparency in that area.	2