Fortum Disclosure Scorecard

Detailed assessment of Fortum's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of Fortum'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 Fortum, 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:

  • Accuracy of Climate Policy Engagement Disclosures: An assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
  • Robustness of Corporate Climate Policy Engagement Review & Misalignment Management Processes: An assessment of the quality and robustness of a company's process to identify, report on, and address specific cases of misalignment between its climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.

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 Fortum's company profile - is accessible via the buttons on the right hand side of the page.

Accuracy of Climate Policy Engagement Disclosure: Summary

A summary of Fortum'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.

IndicatorScore
Accuracy of Climate Policy Engagement DisclosurePartial, meets some criteria
Sub-IndicatorScore
Accuracy of Direct Climate Policy Engagement DisclosureYes, meets criteria
Accuracy of Indirect Climate Policy Engagement DisclosurePartial, meets some criteria

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Summary

A summary of Fortum'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 ReviewScore
December 20225/14 (36%)
2023 (No Date)6/14 (43%)
April 20255/14 (36%)

Accuracy of Climate Policy Engagement Disclosure: Scorecard

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 Fortum'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)?

Fortum

Fortum has published an accurate and largely complete account of its positions and engagement activities on specific climate-related policies, but appears to have excluded 1 case of material evidence of direct climate policy engagement identified by InfluenceMap's database.

On its corporate website, Fortum provides links to position papers and consultation responses as well as providing its EU and Finnish Transparency Register reference numbers. On these pages the company discloses positions and engagement with key legislation including the EU 2040 Target and the EU Renewable Energy Directive Delegated Act on Low Carbon Hydrogen.

Fortum also discloses some positions and engagement activities in its 2024 Climate Lobbying Review. However, Fortum does not appear to have disclosed its joint letter to policymakers detailing its position on the EU Emissions Trading System (ETS).

Best Practice

Enel 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. Enel included its climate advocacy activities, positions, and links to the company’s government consultation responses to specific climate-related policies from 2022-2024 in its 2023 Climate Policy Advocacy report, published April 2024. It also covered a range of regions in its disclosure, including Global, Europe, North & South America, Africa, and the Asia Pacific.

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. It also contains sorting options for most recent, and most relevant.

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)?

Fortum

Fortum has published a partial account of its industry associations' positions and engagement activities on specific climate-related policies. Fortum has disclosed links to position papers and other resources relating to its industry associations' positions and engagement activities on specific climate-related policies, such as the EU Emissions Trading System and the EU 2040 target.

However, Fortum excludes material evidence of indirect climate policy engagement identified by InfluenceMap's database for more than 3 industry associations. For example, Fortum does not appear to have fully disclosed advocacy from Hydrogen Europe including: support of the EU sustainable aviation fuel (SAF) mandate under ReFuel EU Aviation in a September 2024 open letter to EU policymakers, support for emissions trading; advocating for the UK and EU ETS to be linked in an April 2025 joint letter to policymakers, or advocacy for a weakening the EU Hydrogen and Gas Decarbonization Package Delegated Act on the definition of low-carbon hydrogen in October 2024 feedback.

Fortum also does not appear to have fully disclosed Eurelectric's advocacy on the EU Methodology to determine the greenhouse gas (GHG) emission savings of low-carbon fuels, in support of the EU Hydrogen and Gas Decarbonization Package Delegated Act on the definition of low-carbon hydrogen in October 2024 comments.

See Appendix A below for details of the company's industry association memberships.

Best Practice

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. Iberdrola published a largely complete and accurate of its industry associations' positions and engagement activities on specific climate-related policies.

Iberdrola and its North American subsidiary Avangrid both disclosed the climate policy engagement activities of their industry associations in their respective industry association climate lobbying reviews.

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Scorecard - 5/14 (36%)

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 Fortum's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.

Review ProcessReview Assessment (Direct)Review Assessment (Indirect)
Monitor & ReviewIdentify & AssessIdentify & Assess
Alignment Assessment MethodActAct
Framework for Misalignment

The tables below provide: (1) a breakdown of Fortum's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.

Review Process

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?

Fortum

Fortum published its first full review in 2021 with an update in 2022 and 2023. Fortum committed to publish a thorough assessment in 2024 aiming to address the gaps identified by InfluenceMap's previous assessment. This assessment was published in April 2025 and Fortum has now committed to publishing its Climate Lobbying Review every other year.

Best Practice

Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2024, 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?

Fortum

Fortum has disclosed a methodology for assessing the alignment of its industry associations, however it lacks clarity on how the methodology was applied in practice, and only includes top-line explanations behind each finding. As a result, it is unclear the extent to which Fortum has assessed its industry associations’ detailed policy engagement against the 1.5°C goal of the Paris Agreement.

Fortum states in its 2025 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 both our direct and indirect lobbying,” and states that “Fully Aligned” associations have a position consistent with the Paris Agreement and Fortum’s climate advocacy principles.

This review was carried out by assessing how closely the associations align with Fortum’s seven climate advocacy principles, including: climate science and the Paris Agreement, climate neutrality goal, carbon pricing, policy coherence, technology neutrality, energy transition, and carbon removal and negative emissions. Fortum categorized each industry association into 4 groups for each advocacy principle; “Fully Aligned”, “Partially Aligned”, “No Position”, and “Misaligned”.

Fortum assessed alignment against the seven aforementioned climate advocacy principles, and then gave an overall alignment assessment for each association. It provided explanations behind its assessment for each of the 7 assessment criteria.

However, Fortum has only assessed the top-line positions of its industry associations, rather than assessing their detailed climate advocacy positions and activities against science-aligned policy pathways for delivering the 1.5ºC goal of the Paris Agreement. The company does state in its review that “This review focused on top-line policies of the associations without assessing how they are applied in practice. In the future, we aim to assess – where appropriate – also the engagement intensity (advocacy activities) that flow from the associations’ policies.”

Best Practice

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?

Fortum

Fortum states it has a consultative approach to address any identified partial alignments, and it will continue the dialogue and encourage the association to adjust its position and advocacy to reach an aligned conclusion and agree on a way forward. In the case of continued misalignment the company states that depending on the importance of the topic, the extent of the partial alignment and the overall value of the membership, Fortum may also take further steps, however it believes that an industry association’s continuous improvement is more important and constructive than setting deadlines to reach alignment.

The company states it will first continue in the association, but pursue its advocacy independently or through other associations or coalitions. If an industry association’s position cannot be made consistent with Fortum, or no improvement is being made to reach full alignment within a reasonable period, the issue may be escalated to the relevant business owner in the company. At this point, Fortum states it may reassess its membership, including ending activities such as board and committee participation, or ending overall membership.

Fortum has not however attached clear deadlines to this framework for industry associations that do not reform misaligned climate policy engagement practices.

Best Practice

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.

Review Assessment (Direct - Company)

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)?

Fortum

Fortum 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. This applies to both our direct and indirect lobbying,” and the company provides a section of the report dedicated to a "Review of Fortum’s own climate lobbying positions." However, details of the assessment of its climate policy engagement activities are not disclosed, and it is therefore unclear to what extent the company has reviewed its direct engagement activities. 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. InfluenceMap's analysis indicates that Fortum has less than 3 cases of potentially misaligned material advocacy.

For example, the company has not publicly reviewed potentially misaligned advocacy including October 2024 comments submitted to the European Commission, where Fortum supported the EU Hydrogen and Gas Decarbonization Package Delegated Act on the definition of low-carbon hydrogen with major exceptions. In its response, the company appeared to advocate for a revision that may enable companies to circumvent stricter production criteria for renewable hydrogen as finalized by the EU Commission in 2023.

At the time of this assessment, Fortum’s InfluenceMap Organization Score was 60%, indicating partial misalignment between its detailed climate policy engagement and policy pathways for delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. Fortum also has an engagement intensity of 47% which indicates highly strategic climate policy engagement with a mixture of positive and negative positions. Please see the Fortum’s profile in the LobbyMap database for additional details on the company's real-world climate policy engagement activities.

Best Practice

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 in August 2023. 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. The company has not updated its review in 2024.

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?

Fortum

Fortum 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 such, the company has shown no evidence of action to address cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement.

Best Practice

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.

Review Assessment (Indirect - Industry Associations)

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?

Fortum

In its review, Fortum assessed 11 associations. It excluded 2 associations actively engaged on climate policy covered by InfluenceMap’s database; the Federation of Indian Chambers of Commerce & Industry (FICCI), and the Associated Chambers of Commerce and Industry of India (ASSOCHAM). Fortum states “India is no longer part of Fortum’s strategy, although we still maintain minor business operations in the country ... memberships in Indian associations are no longer relevant to us,” however InfluenceMap’s analysis still considers these to be material relationships and therefore has included them in its assessment.

Fortum found 4 of the associations reviewed to be fully aligned, including Hydrogen Europe, 5 to have partial alignment, including WindEurope, and 2 associations did not have official positions on one of the key principles (Eurelectric and SolarPower Europe).

InfluenceMap’s analysis indicates that the company has no memberships to industry associations that are misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database). However, the company has 4 memberships to industry associations that InfluenceMap assesses to be partially aligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+). These include Hydrogen Europe, Eurelectric, the Federation of Indian Chambers of Commerce & Industry (FICCI), and the Associated Chambers of Commerce and Industry of India (ASSOCHAM).

Of these associations, Fortum identified full alignment with Hydrogen Europe and identified alignment on every principle except where there was no available position for Eurelectric. The company did not include FICCI or ASSOCHAM. As a result, Fortum did not identify 4 cases of partial misalignment, according to InfluenceMap’s database.

See Appendix A for further details on the company’s industry associations.

Best Practice

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.

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?

Fortum

Fortum states that it has terminated 8 memberships after its last review and cancelled 16 memberships due to divestments of certain businesses. It also mentions its continued discussions with two Polish associations, previously identified as being partially aligned: Polish District Heating Association (IGCP) and Polish Association of Heat Energy (PTEC). Fortum states it will continue to engage with these two industry associations and work constructively with them on climate-related policies to encourage these associations to engage in ongoing and constructive advocacy with the Polish Government in support of the EU 2040 target and reaching net-zero emissions by 2050.

However, Fortum does not appear to have addressed other key cases of partial misalignment with policy pathways for delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.

Best Practice

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.

Key

Yes, meets criteria

Partial, meets some criteria

No, does not meet criteria

Appendix A: Fortum's Industry Association Memberships

The table below provides a ranking of Fortum'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:

  • Aligned = Performance Band A+ to B
  • Partially Misaligned = Performance Band B- to D+
  • Misaligned = Performance Band D to F
  • Low Engagement = Performance Band N/A

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.

Industry AssociationInfluenceMap Performance BandInfluenceMap Assessment
SolarPower EuropeB+Aligned
WindEuropeB+Aligned
EurelectricB-Partially Aligned
Associated Chambers of Commerce and Industry of India (ASSOCHAM)C+Partially Aligned
Federation of Indian Chambers of Commerce & Industry (FICCI)C+Partially Aligned
Hydrogen EuropeCPartially Aligned