Repsol SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Repsol provides an extensive and detailed account of its climate-policy advocacy. It names a wide range of specific measures it has engaged on, including the Emissions Trading System reform, the Renewable Energy Directive (REDIII), the Carbon Border Adjustment Mechanism, ReFuelEU Aviation, the Energy Efficiency Directive, the EU Methane Strategy, the Regulation on CO2 standards for light-duty vehicles, the Spanish Climate Change and Energy Transition Law and the PNIEC, among others, demonstrating a very high level of transparency about the exact legislation it seeks to influence. The company also explains how it engages: it “answered to EC public consultations related to the Carbon border adjustment mechanism proposal”, submitted feedback to the draft ETS State Aid Guidelines, took part in expert working groups in associations such as FuelsEurope and IETA, and held “direct meetings with policymakers” on Spanish climate legislation, clearly identifying its targets as the European Commission, EU legislators and national Spanish lawmakers. Finally, Repsol sets out the concrete results it pursues, advocating, for example, for “greater protection against the risk of carbon leakage” while supporting higher ETS prices, asking that the ReFuelEU Aviation rule “be more closely aligned with the Renewable Energy Directive, without establishing additional restrictions on eligible raw materials”, proposing a methane-intensity performance standard of <0.20 % by 2025, and calling for “the standard and the default values … to be more flexible in order to recognize alternative production pathways.” These specific, measurable requests show the company is explicit about the policy changes it is seeking, why it supports them and the benefits it expects. Taken together, the disclosures reflect comprehensive transparency across the policies lobbied, the mechanisms employed and the outcomes sought.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Repsol has developed a structured approach to govern its lobbying with industry associations, noting that we regularly assess the alignment between key associations and our climate policy positions and publicly publishing an annual report on Repsols participation in trade associations that categorizes associations as aligned, partially aligned, or non-aligned. To that end, the company has implemented an assessment approach that includes the following steps: 1. Identify main initiatives and associations. 2. Assess whether the associations positions are consistent with both the fulfilment of the goals of the Paris Agreement and our climate policy positions. 3. Act to address all cases of potential misalignment. 4. Monitor and review lobbying activities and alignment with Repsols climate positions once a year, disclosing publicly the results of this assessment, a process driven by corporate teams (Sustainability, Institutional Relations, and Investors Relations alongside business and regional units). Oversight is provided by the Boards Sustainability Committee, which supervises and periodically monitors ... participation in industry initiatives and associations and their alignment with the Companys climate position and reports its findings to the full Board. However, the company does not disclose a parallel governance mechanism for its direct lobbying effortsthere are no named individuals, sign-off steps, or dedicated review processes for its own advocacy beyond general compliance statements that lobbying activities should be undertaken transparently and that costs are reported under transparency registers. This suggests robust governance of indirect association lobbying but an absence of an equivalent framework for Repsols direct policy engagement.	2