Uniper SE

Uniper discloses high-level sustainability oversight structures but provides very limited information on how it governs climate-related lobbying. It states that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement" and that "Discussions on the decarbonization strategy and the concrete measures were increasingly held in 2021 [...] through the Sustainability Council", indicating an intention to align external engagement with its climate strategy. Governance bodies such as the Sustainability Committee of the Supervisory Board, which "monitors the effectiveness of Uniper's ESG policies and procedures and the sustainability strategic plan (SSP)", and the Sustainability Council, which is "a cross-functional body that meets on a quarterly basis to oversee the implementation of Uniper's sustainability strategy and governance framework", are clearly identified. However, the evidence does not specify whether these bodies review or approve direct lobbying positions, monitor the company's interactions with policymakers, or assess the climate-policy stances of trade associations; nor does it describe any formal process for correcting or exiting misaligned associations. We found no disclosure of a dedicated lobbying policy, no description of alignment checks for direct or indirect advocacy, and no published review or audit of lobbying activities. Consequently, while there is a general commitment to Paris-aligned engagement and some senior-level ESG oversight, the company does not disclose a concrete governance framework for climate lobbying alignment beyond these statements, indicating only limited governance in this area.