Novolipetsk Steel PJSC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Novolipetsk Steel PJSC offers only minimal insight into how it governs climate-related lobbying. In answering how it “ensure[s] that your engagement activities are consistent with your overall climate change strategy,” the company states that it “engages actively in cooperation with Russian and international regulators to pursue reduction of environmental and climate impacts” and that it “takes active part in the work of several regulatory committees… as well as the working group responsible for developing steel decarbonization strategy in Russia.” This language indicates an intention to align external advocacy with its climate objectives, but it stops short of detailing any internal oversight, sign-off, or monitoring mechanism. No disclosure identifies a board committee, senior executive, or other formal body that reviews or approves lobbying positions, and the company explicitly notes “No, and we do not plan to have one in the next two years” when asked about a public commitment to conduct engagement in line with the Paris Agreement. Likewise, although it “collects and submits data on sustainability indicators on an annual basis,” there is no explanation of how this activity feeds into an audit or assessment of lobbying alignment. Overall, the disclosure references the intent to align engagement with climate goals but provides no tangible governance structure, oversight responsibility, or review process, indicating only limited governance of climate lobbying. View Sources	D

Overall Assessment

Analysis

Score

Limited

Novolipetsk Steel PJSC offers only minimal insight into how it governs climate-related lobbying. In answering how it “ensure[s] that your engagement activities are consistent with your overall climate change strategy,” the company states that it “engages actively in cooperation with Russian and international regulators to pursue reduction of environmental and climate impacts” and that it “takes active part in the work of several regulatory committees… as well as the working group responsible for developing steel decarbonization strategy in Russia.” This language indicates an intention to align external advocacy with its climate objectives, but it stops short of detailing any internal oversight, sign-off, or monitoring mechanism. No disclosure identifies a board committee, senior executive, or other formal body that reviews or approves lobbying positions, and the company explicitly notes “No, and we do not plan to have one in the next two years” when asked about a public commitment to conduct engagement in line with the Paris Agreement. Likewise, although it “collects and submits data on sustainability indicators on an annual basis,” there is no explanation of how this activity feeds into an audit or assessment of lobbying alignment. Overall, the disclosure references the intent to align engagement with climate goals but provides no tangible governance structure, oversight responsibility, or review process, indicating only limited governance of climate lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Novolipetsk Steel PJSC provides a high level of transparency around its climate-policy lobbying. It names two specific measures it has worked on—the “Federal Law on Limiting GHG emissions N 296-FZ” in Russia and the EU’s planned Carbon Border Adjustment Mechanism (CBAM)—and explains the context and scope of each. The company is equally explicit about how it lobbies, referring to “meetings with SOGEPA and the Walloon Government, as well as the ministries of Belgium and Denmark,” “participation in the EC’s public consultations,” work through the “Eurofer carbon tax working group,” and its broader “contribut[ion] to the development of the Law on GHG emissions.” These references identify both the mechanisms (meetings, consultations, working groups) and the targets (national ministries, EC Directorates, climate NGOs) of its advocacy. Finally, the company spells out the outcomes it seeks: it “fully supports the current version of the law” on Russian GHG regulation, and for CBAM it presses for “a differentiated approach based on the ‘polluter pays’ principle” and a phased introduction “step-by-step, starting with sectors with less complexity and trade flow involvement.” This combination of clearly identified policies, detailed engagement channels, and concrete desired legislative results demonstrates strong transparency in its climate lobbying disclosures.	B