This scorecard provides a detailed breakdown of InfluenceMap's assessment of Shell's disclosures on climate policy engagement. This does not include an assessment of the company's real-world climate policy engagement, which can be found on InfluenceMap's online profile of Shell, accessible via the buttons on the right hand side of the page.
The disclosure assessments are directly integrated into the CA100+ Net Zero Company Benchmark as part of InfluenceMap's Climate Policy Engagement Alignment’ assessment, under two distinct indicators:
In 2023, InfluenceMap’s methodology to assess corporate disclosures on climate policy engagement was formally updated in line with the Global Standard on Responsible Climate Lobbying and stakeholder input. The detailed methodology - as well as additional resources including best practice guidance and Shell's company profile - is accessible via the buttons on the right hand side of the page.
A summary of Shell's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
| Indicator | Score |
|---|---|
| Accuracy of Climate Policy Engagement Disclosure | Partial, meets some criteria |
| Sub-Indicator | Score |
|---|---|
| Accuracy of Direct Climate Policy Engagement Disclosure | Partial, meets some criteria |
| Accuracy of Indirect Climate Policy Engagement Disclosure | Partial, meets some criteria |
A summary of Shell's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
The Review Score (0-100) assesses corporate performance against seven indicators, using the same traffic-light framework. A ‘Green’ scores 2 points, a ‘Yellow’ scores 1 point, and a ‘Red’ scores 0 points. This total is converted into a percentage from 0 to 100, calculated using the total number of points available (14). As such, only certain scores within the 0 to 100 range are possible under this methodology. A Review Score of 100 would indicate that a company has met all of the assessment criteria related to the review process.
| Date of Review | Score |
|---|---|
| April 2023 | 5/14 (36%) |
| April 2024 | 5/14 (36%) |
This is an assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
InfluenceMap utilizes its proprietary database to assess how corporate disclosures on climate policy positions and engagement activities compare to InfluenceMap's independent assessment of the companies' and industry associations' real-world climate policy engagement. In short, it assesses the extent to which the company has disclosed on all climate policy engagement identified by InfluenceMap's database.
The tables below provide: (1) a breakdown of Shell's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company published an accurate account of its corporate climate policy positions and engagement activities (as compared to InfluenceMap’s database)?
Shell has published a partial account of its positions and engagement activities on specific climate-related policies, but appears to exclude more than 3 material evidence of direct climate policy engagement identified by InfluenceMap's database.
Shell has disclosed its position on, and engagement with, specific climate-related policies in 2023 in several regions in which it operates including Australia, the EU, US, Canada and the Netherlands.
However, Shell does not appear to have disclosed a complete and accurate account of its climate policy engagement activities. For example, it does not appear to have disclosed Its engagement with the Australian Coal Orderly Exit Management Framework in February 2024, its submission to Scotland's Draft Energy Strategy and Just Transition Plan in May 2023, its comments to policymakers in India on Guiding Principles for Declaring CGD Common or Contract Carrier in April 2023, or its comments on the UK's Low Carbon Hydrogen Certification Scheme, also in April 2023.
Rio Tinto has published a complete and accurate account of its positions and engagement activities on specific climate-related policies, and this is aligned with InfluenceMap's assessment of the company using its LobbyMap database. Rio Tinto discloses links to the company's government consultation responses to specific climate-related policies from 2020-2023, including the Australian Government's Safeguard Mechanism Reforms, Guarantee of Origin Scheme and Technology Investment Roadmap, in addition to New Zealand's Emissions Trading Scheme, and amendments to New Zealand's Climate Change Response Act 2002. Rio Tinto does not appear to have excluded any material evidence of climate policy engagement.
BP partially met the assessment criteria under this indicator, as it excluded material evidence of climate policy engagement. However, BP’s ‘Advocacy Activities’ webpage provides a clear and detailed disclosure of the company’s climate policy engagement, with filters for jurisdiction; date; and topic, including links to relevant consultation responses.
Has the company published an accurate account of the climate policy positions and engagement activities of the industry associations of which it is a member (as compared to InfluenceMap’s database)?
Shell discloses a list of its industry association memberships on its corporate webpage. However, it appears to omit 27 industry associations which are actively engaged on climate-related policy such as the Federation of Indian Petroleum Industry (FIPI), Federation of German Industries (BDI), Natural & Bio Gas Vehicle Association and Instituto Brasileiro de Petróleo e Gás (IBP).
Shell provided an update to its 2022 Climate and Energy Transition Lobbying Report in May 2024, for the year 2023. However, Shell excludes material evidence of indirect climate policy engagement identified by InfluenceMap's database for more than 3 industry associations.
For example, Shell did not appear to fully disclose the Australian Energy Producers engagement on the Australian Hydrogen Strategy review in August 2023, the American Petroleum Institute's engagement on the EPA's tailpipe emissions standards for light and medium-duty vehicles in December 2023, the US Chamber of Commerce Comments on the National Environmental Policy Act Implementing Regulations Revisions in September 2023, or the National Association of Manufacturers engagement on the Environmental Protection Agency's proposed Power plant Rules in August 2023.
See Appendix A below for details of the company's industry association memberships.
BHP has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. For example, BHP has disclosed engagement by 7 of its industry associations on Australia's Safeguard Mechanism Reforms, including links to their consultation responses. While BHP has disclosed links to the climate policies and consultations its industry associations have engaged with, it is not clearly referenced within the disclosure and does not provide a detailed description of the positions taken by its industry associations on some of these policies.
Unilever has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. In its March 2024 industry association review, the company attached LobbyMap profile links to each association’s assessment.
This is an assessment of the quality and robustness of a company's processes to identify, report on, and address specific cases of misalignment between its climate policy engagement activities (direct and indirect) and delivering the 1.5°C goal of the Paris Agreement.
The Review Score is split into seven indicators, which fall within one of three categories:
Review Process: Does the company have clear and robust governance processes to regularly assess alignment against the 1.5°C goal of the Paris Agreement, and address potential cases of misalignment?
Review Assessment (Direct - Company): Has the company identified and addressed specific cases of misalignment between its direct - i.e. corporate - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
Review Assessment (Indirect – Industry Associations): Has the company identified and addressed specific cases of misalignment between its indirect – i.e. via industry associations - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
The table below provides an overview of Shell's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.
| Review Process | Review Assessment (Direct) | Review Assessment (Indirect) |
|---|---|---|
| Monitor & Review | Identify & Assess | Identify & Assess |
| Alignment Assessment Method | Act | Act |
| Framework for Misalignment |
The tables below provide: (1) a breakdown of Shell's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company established an annual monitoring and review process to ensure that all of its direct and indirect climate policy engagement activities across all geographies are consistent with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels?
Shell has published an annual review of its industry associations’ since 2019. These reviews include a comprehensive report every two years, with interim updates provided in the alternate years. According to Shell's 2023 Climate and Energy Transition Report, published in May 2024, the company plans to release its next full review in 2025.
Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2023, with detailed updates on misaligned industry associations each year. The company has committed to continue reviewing its memberships on an annual basis. Alternatively, Shell publishes a detailed review of its climate policy engagement every two years, with a detailed update in the interim year.
Has the company disclosed a clear and detailed framework for assessing alignment, including: (1) the criteria it uses to assess whether its climate policy engagement activities (direct or indirect) align with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels; and (2) a clear and detailed explanation behind each evaluation?
Shell's 2024 industry association update cites the methodology set out in its full 2023 review. The alignment assessment method includes assessing its associations against 15 criteria based on Shell’s own global climate and energy transition policy positions. These broadly include top-line climate policy positions including support for the Paris Agreement, positions on carbon pricing, positions on the energy transition and energy types, and positions on the electrification of light- and heavy-duty transport, aviation, heavy industry, and shipping.
It is unclear whether Shell’s alignment assessment of its industry associations’ policy positions and activities are benchmarked against the 1.5°C goal of the Paris Agreement. Shell states in its review that it is “committed to lobbying for policy positions that we believe are in line with the goals of the Paris Agreement and the world achieving net-zero emissions by 2050. This applies to our direct and indirect lobbying.” However, in its methodology, the company appears to have only assessed its associations’ top-line support for the Paris Agreement.
Shell’s methodology also includes assessment criteria on the energy transition and the electrification of various industries, based on Shell’s own positions on these issues. However, the company does not appear to have assessed its own positions against the 1.5°C goal of the Paris Agreement, and therefore it is unclear if its own policy positions represent science-aligned advocacy. For example, Shell states that its position on gas includes ‘Support for policies that recognize natural gas and other low-carbon gases as partners for renewable sources.’ InfluenceMap's analysis suggests this is misaligned with IPCC guidance on the role for fossil gas in the energy transition. As such, a finding of alignment by the company against its own policy positions may not constitute alignment to science-based climate policy pathways for delivering the 1.5°C goal of the Paris Agreement.
The full 2023 review did however provide criteria which were used to categorize the degree of alignment of Shell’s policy positions on climate change with the positions of its associations, and provided explanations on how each evaluation was conducted.
Unilever is the only company to have met the assessment criteria under this indicator. Unilever assessed its industry associations’ climate policy engagement against both its own climate policy positions, and against science-based policy, determined by “what the Intergovernmental Panel on Climate Change (IPCC) has said is needed to keep global warming below 1.5°C”. Unilever states that this assessment does not mean associations should be expected to support every proposed climate law, but that when an association opposes a specific climate policy, it is incumbent on the association to engage constructively with policymakers to help find alternative, viable policy options that would be (at least) equally effective at reducing emissions.
The company also clearly disclosed the criteria for findings of alignment and misalignment with both its own policy positions and science-based policy, and measured the engagement intensity of each association. It also provided clear and detailed explanations behind each evaluation including their detailed policy positions and links to each industry association’s LobbyMap profile.
Has the company established a clear framework to address misalignments between its climate policy engagement activities (direct or indirect) and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, including the escalation strategies it will use and when it will use these escalation strategies?
Shell has disclosed a clear and detailed framework for addressing misalignments, including escalation strategies. This includes remaining in the association and increasing Shell’s engagement in areas where misalignment has been identified; pursuing advocacy independently or through other associations; reassessing membership including ending activities such as board and committee participation; or ending overall membership.
However, there are no deadlines attached to this framework for industry associations that do not reform misaligned climate policy engagement practices.
Iberdrola has disclosed a clear and detailed framework to address potential misalignments, including escalation strategies and deadlines for industry associations that do not amend misaligned practices. Iberdrola's escalation strategy includes engagement with the industry association, sending a "notification of dissatisfaction", and formal notification that a termination of membership is being assessed. If the association does not provide a clear and credible action plan to address the misalignment within 12 months, Iberdrola will implement one or more of the following actions: make a clear public statement regarding the misalignment, request the industry association refrains from engaging on misaligned issues, and/or suspension or discontinuation of membership.
Has the company identified and reported on the existence of all misalignments between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database (including all of its subsidiaries, business areas, and operational jurisdictions)?
Shell's 2023 Climate and Energy Transition Report, published in May 2024 includes a ‘Direct Lobbying Review’ for activities in calendar year 2023. This review details some of Shell’s lobbying activities across 11 different policy areas.
While the company states that it is “committed to lobbying for policy positions that we believe are in line with the goals of the Paris Agreement and the world achieving net-zero emissions by 2050”, the company does not appear to have carried out an assessment of the degree of alignment of its direct lobbying activities against the 1.5°C goal of the Paris Agreement. As such, Shell does not appear to identify or report on the existence of misalignments between its direct climate policy engagement activities and the 1.5°C goal, in line with InfluenceMap’s database.
For example, Shell’s direct lobbying review did not include the company's opposition to Canada’s proposed Clean Electricity Regulations in November 2023 comments or its apparent unsupportive September 2023 comments on the US National Environmental Policy Act Implementing Regulations Revisions Phase 2. Shell’s direct lobbying review also did not include its comments on Western Australia’s Domestic Gas Policy in August 2023, in which it advocated for policy measures to facilitate new fossil fuel production.
At time of this assessment, Shell's Organization Score metric was 66%, indicating partial misalignment between the Paris Agreement and the company’s detailed climate policy engagement. Please see Shells profile in the LobbyMap databased for additional details on the company's real-world climate policy engagement activities.
Danone assessed 12 of its own climate policy positions and engagement activities across Europe, the US, and globally. It found all 12 to be aligned. According to InfluenceMap’s database, Danone does not appear to have any material evidence of negative climate policy engagement during the reporting period. As a result, Danone has assessed its climate policy engagement activities in line with InfluenceMap’s findings. It is the only company to have ‘broadly met’ the criteria for this indicator.
Sasol published a detailed review of its direct climate policy engagement. Sasol assessed the alignment of five of its own climate policy positions, including four in South Africa (Climate Change Bill; Carbon Tax; PCC Just Transition Framework; Upstream Oil and Gas Tax Regime Discussion Document) and one in the EU (European Union Delegated Acts). However, Sasol did not identify any cases of misalignment with its own climate policy engagement. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
As a result, no company has shown evidence of identifying cases of misalignment of its direct climate policy engagement and delivering on the 1.5°C goal of the Paris Agreement.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
In its 2023 Climate and Energy Transition Report, published in May 2024, Shell does not identify any instances of misalignment between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre - industrial levels, in line with InfluenceMap's database. Therefore, Shell has shown no evidence of action to address cases of misalignment.
Danone and Unilever are the only companies to have ‘broadly met’ the criteria for this indicator by default. Both companies do not appear to have any material evidence of negative climate policy engagement according to InfluenceMap’s database, and therefore have no cases of misalignment to act upon.
As a result, no company has actively shown evidence of acting to address cases of misalignment between its own direct climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.
Has the company identified and reported on the existence of all misalignments between the climate policy engagement activities of its actively engaged industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
In its 2023 Climate and Energy Transition Report, published in May 2024, Shell focuses on the 10 associations it found to have partial misalignment in its most recent full review, published in 2023. Shell appears to find that these associations continue to be partially misaligned, and does not state that any of these associations have changed to either “aligned” or “misaligned”.
These 10 associations include: the American Petroleum Institute (API); Australian Energy Producers (AEP, formerly Australian Petroleum Production & Exploration Association); Canadian Association of Petroleum Producers (CAPP); Chamber of Minerals and Energy of Western Australia (CME); International Gas Union (IGU); National Association of Manufacturers (NAM); Queensland Resources Council (QRC); Texas Oil & Gas Association (TXOGA); U.S. Chamber of Commerce (USCC); and the Western States Petroleum Association (WSPA).
InfluenceMap analysis indicates that the company has 26 memberships to industry associations with active climate policy engagement misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database). InfluenceMap analysis also indicates that Shell has a further 31 memberships to industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+). According to InfluenceMap’s database, 9 of the associations Shell has assessed are misaligned, with 1 partially misaligned (IGU).
Shell has not identified the remaining 47 cases of misalignment and partial misalignment between its industry associations and delivering the 1.5°C goal of the Paris Agreement in line with InfluenceMap’s database.
See Appendix A below for further details on the company’s industry association memberships.
Unilever assessed 27 industry associations in its review and identified all cases of misalignment and partial misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database. Unilever has membership to 1 misaligned industry association (Tennessee Chamber of Commerce & Industry), and 10 partially aligned associations.
Enel assessed 97 associations in its review and identified all cases of misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database: Confindustria, Spanish Confederation of Business Organizations (CEOE), and Edison Electric Institute - although the company does not disclose additional details of why each industry association is not fully aligned.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between the climate policy engagement activities of its industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
In its 2023 Climate and Energy Transition Report, published in May 2024, Shell outlines some evidence of action to address ongoing misalignments between its industry associations and delivering the 1.5°C goal of the Paris Agreement. Shell ended its membership with Queensland Resources Council in 2023, stating that it would focus its advocacy with the national association, Australian Energy Producers (formerly APPEA).
Some examples of actions Shell states it will take include encouraging Texas Oil & Gas Association (TXOGA) to be transparent around its advocacy on carbon, capture and storage (CCS), hydrogen, and energy efficiency; urging the Australian Energy Producers to support regulations for reducing methane emissions; encouraging the International Gas Union to explicitly support net zero emissions by 2050; and pushing the Canadian Association of Petroleum Producers (CAPP) to support electrification and renewable power.
However, Shell does not appear to have shown evidence of action to address specific cases of misalignment and partial misalignment with delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
Unilever is the only company to have met investor expectations in this area, showing evidence of action to address all cases of misalignment between its industry associations and delivering the 1.5⁰C goal of the Paris Agreement, as identified by InfluenceMap’s database. In its review, the company included a section for each association titled “Actions (to be) taken” in which it outlined the actions taken or to be taken with the industry association as per its assessment. For example, Unilever stated that it would write to the Tennessee Chamber of Commerce & Industry stating that their positions do not reflect those of Unilever. It also disclosed it would encourage the European Roundtable for Industry to continue to engage constructively on the EU Green Deal and explore how it can revise its position on the EU Emissions Trading System.
Additionally, Unilever stated that for the 12 associations that were deemed “passively aligned” (minimal to non-existent policy engagement), the company will aim to push the associations to become more actively engaged in promoting outcomes and policies that aid in decarbonization.
Yes, meets criteria
Partial, meets some criteria
No, does not meet criteria
The table below provides a ranking of Shell's industry associations currently covered by InfluenceMap’s database by Performance Band, i.e. a full measure of a company’s climate policy engagement, accounting for both its own engagement and that of its industry associations. Detailed profiles for all industry associations can be explored via the links in the table.
Industry associations are categorized by InfluenceMap as having climate policy engagement that is aligned, partially misaligned or misaligned with delivering the 1.5°C goal of the Paris Agreement by Performance Band:
The ranking table below is updated automatically on a continual basis as: (1) new evidence is collected for the industry associations; (2) new industry associations are added to the company profile; (3) industry associations are removed from the company profile, e.g. if the company leaves the association.
As such, the industry associations and/or scores in the ranking table below may differ from the findings in Identify & Assess (Indirect) above, which was written on the date of assessment. See the top of this page for the date of assessment.
