Orlen SA

ORLEN SA demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate change. The company has implemented a Compliance Policy that includes standards for lobbying, managed by the ORLEN Financial Control, Risk and Compliance Management Office, which is tasked with "implementation, management, updating and communication of the Compliance Policy and the supporting procedures for regulatory risk management, compliance with license requirements and lobbying." Additionally, the Climate and Sustainability Council oversees the Climate Policy, ensuring its application across the ORLEN Group and requiring companies within the group to report on its delivery. The Council also uses the Integrated Management System controls to monitor and rectify inconsistencies in the Climate Policy's application. ORLEN SA is active in various organizations advocating for climate-related public policy, such as CO2Value Europe and Hydrogen Europe, and contributes expert knowledge and opinions to these initiatives. However, while the company has disclosed oversight mechanisms and engagement in climate-related advocacy, there is no evidence of a detailed process for aligning lobbying activities with climate goals or a published lobbying audit/review. Furthermore, the disclosures do not explicitly address how indirect lobbying through trade associations is monitored or managed to ensure alignment with climate objectives.