SSE PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	SSE PLC demonstrates a very high level of transparency about its climate-policy advocacy. It names a wide range of identifiable measures it engages on, including the UK Government’s “Review of Electricity Market Arrangements (REMA)”, reforms to “Transmission Network Use of System (TNUoS) charging”, the EU “Energy Efficiency Directive” and “Fit-for-55” package, Ireland’s “Climate Action Plan 2021”, the UK Cluster Sequencing Process for carbon capture and storage, the Scottish “Heat in Buildings Bill”, and multiple other consultations on hydrogen strategy, offshore wind auctions, long-duration electricity storage and marine planning rules. SSE also explains in detail how it seeks to influence these files. It records more than 150 direct COP-related engagements, meetings with the UK Prime Minister, Energy Ministers and the Taoiseach, submissions to BEIS, Ofgem and DESNZ consultations, participation on government-run task forces such as the Offshore Wind Acceleration Task Force, and indirect work “via Eurelectric”, RenewableUK, Hydrogen UK and other trade associations; each mechanism is linked to specific targets such as the European Commission, UK and Scottish Governments and Irish Departments. Crucially, the company is explicit about the concrete outcomes it is pursuing: for example, it calls for “a Government commitment to five power-CCS projects in the 2020s”, seeks to raise the UK offshore-wind target to 50 GW by 2030 and Ireland’s onshore-wind capacity to 8 GW by the same date, argues that CfDs should be extended to all non-flexible low-carbon generation, opposes locational marginal pricing because “we can’t see how the benefits of such a change can outweigh the costs”, and supports linking the UK and EU ETS to avoid a Carbon Border Adjustment Mechanism. It also advocates for a “cap-and-floor” regime for pumped-storage hydro, reforms to planning consent timelines, and a review of TNUoS to unlock Scottish renewable projects. By clearly identifying the legislation it works on, the channels it uses and the specific policy changes it seeks, SSE provides comprehensive disclosure of its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	SSE PLC demonstrates a comprehensive governance process for climate lobbying, with clear mechanisms for ensuring alignment with its climate-related goals and the Paris Agreement. The company conducts an annual review of its trade association memberships to ensure their policy positions align with SSEs principles on climate change, stating that "SSE works closely and engages with these trade associations on a continuous basis to ensure that their principles on climate change are consistent with those of its own." SSE has published detailed Trade Association Climate Reviews annually, which include the scope, methodology, and results of its assessments, such as the 2022/23 review where "of the 28 trade associations which were in scope, 22 were found to be fully aligned and six partially aligned." The company commits to transparency by disclosing these reviews publicly and taking action where misalignment is identified, including engaging with associations to influence their positions or exiting memberships if necessary. SSEs governance framework includes oversight by the Board, which monitors the implementation of its Political Engagement Policy and advocacy priorities, ensuring alignment with external landscapes. The Chief Executive retains ultimate responsibility for climate-related initiatives, supported by the Chief Sustainability Officer, who advises on climate matters and the Net Zero Transition Plan. SSEs Corporate Affairs directorate also maintains an overview of trade associations advocacy activities, ensuring continuous alignment. Furthermore, SSE actively advocates for ambitious climate policies, stating that "SSE will only undertake advocacy activity that is in line with the goals of the Paris Agreement and its own net zero strategy." This robust governance process, coupled with detailed disclosures and active alignment actions, indicates strong accountability and transparency in both direct and indirect climate lobbying activities.	4