Legislative Letters

US Environmental Organization Letter to the UNFCCC on Corporate Transparency at COP

Nov 7, 2023

Sarah Bloom Raskin
Dr. Bing Leng
Consultation on the Net Zero Recognition and Accountability Framework
United Nations Framework Convention on Climate Change
P.O. Box 260124 D-53153
Bonn, Germany

Dear Ms. Raskin and Dr. Leng:

We write to you regarding the recently announced United Nations Framework Convention on Climate Change (UNFCCC) Consultation on the Net Zero Recognition and Accountability Framework.

In recent years, there have been growing concerns at the outsized presence and influence that corporations wield in UNFCCC-organized climate negotiations, and that their presence at the annual Conference of the Parties (COP) is an attempt to greenwash their reputations on the global stage. Hundreds of fossil fuel lobbyists attended the last two COPs, with that number growing substantially between COP26 and COP27,[1]  and this year’s COP28 in Dubai will be presided over by the CEO of one of the world’s largest oil and gas companies.[2] Failure to address these concerns will risk delegitimizing and eroding the public’s trust in the key international body responsible for addressing the existential threat of climate change.

Leading up to this year’s COP, therefore, we see an urgent need for transparency. We call on the UNFCCC to push companies and industry associations attending COP to disclose any advocacy, lobbying, and contributions they have made on climate-related issues. This would enable countries party to the COP, members of civil society, and those watching the proceedings around the world to understand the intentions and behavior of corporate representatives with respect to national and subnational laws and regulations that will be required to implement Paris-consistent policy.

This request is neither new nor unique. The UNFCCC’s own Race to Zero campaign has clearly stated the need for non-state actors to disclose their policy engagement activities[3]. The OECD’s Lobbying in the 21st Century[4] advice to member governments echoes this need for transparency around corporate policy advocacy in the context of climate change policy. This need has also been articulated in a public letter signed by US and EU legislators,[5] and more broadly in the context of expectations of investors and shareholders in listed companies.[6]  Bearing these stakeholder demands in mind, the following are three disclosure steps that all companies and industry associations should be required to undertake as a condition of participation at any events convened by the UNFCCC, including COPs:

Commit to Science Based Policy Engagement
Make a public commitment to align climate policy engagement, including via industry associations, with policy recommendations based on IPCC’s guidance on limiting global warming to 1.5⁰C (Science Based Policy).  It is noted that the definition of ‘policy engagement’ should be considered as a broad range of influencing activities defined in The Guide for Responsible Corporate Engagement in Climate Policy, published by a collaboration of UN agencies.[7]

Disclose an audited ‘Climate Policy Influencing Statement/Report’
In line with investor expectations, this report should cover:

  • A comprehensive account of the entity’s direct and indirect (via industry associations) climate policy engagement positions and activities, including monetary contributions to third party agents engaged in climate (industry associations, lobbyists) and any political contributions.
  • A clear assessment of the alignment of these activities benchmarked to the IPCC’s guidance on limiting global warming to 1.5⁰C.
  • A clear action plan to address misalignments.
  • Have the above audited by an independent and reputable third party and/or be prepared to have it undergo rigorous scrutiny for accuracy, completeness, and actual implementation by civil society groups (such as InfluenceMap.org).

COP 28 Transparency
Entities must also provide additional disclosures of COP/COP28 advocacy positions and meetings in advance of the conference, followed by a complete summary when the COP 28 is completed.

We believe that by requiring such clear and verifiable disclosures of corporate actors, the UNFCCC can enhance public trust in the COP process and ensure that it is not abused by corporate actors seeking to undermine climate action or greenwash their reputations.  We would be happy to discuss these matters with you further at your convenience.


League of Conservation Voters

Center for American Progress


Natural Resources Defense Council

Sierra Club

Cc: Simon Stiell, Executive Director, UNFCCC


[1] “636 fossil fuel lobbyists granted access to COP27” Global Witness (Nov. 10, 2022), https://www.globalwitness.org/en/campaigns/fossil-gas/636-fossil-fuel-lobbyists-granted-access-cop27/#:~:text=A%20new%20analysis%20released%20today,than%20in%20Glasgow%20last%20year.

[2] “Inside the Campaign that Put an Oil Boss In Charge of a Climate Summit” The Intercept (Oct. 25, 2023), https://theintercept.com/2023/10/25/cop28-uae-oil-climate-sultan-al-jaber/

[3] The 5th P (Persuade) Handbook, UNFCCC, available at https://climatechampions.unfccc.int/wp-content/uploads/2023/07/Race-to-Zeros-5th-P-Persuade-Handbook-2.pdf

[4] Lobbying in the 21st Century, OECD, available at https://www.oecd.org/corruption-integrity/reports/lobbying-in-the-21st-century-c6d8eff8-en.html

[5] See, May 23, 2023 letter from U.S. and E.U. legislators to President Biden, President von der Leyen, Secretary-General Guterres, and Executive Director Stiell, available at https://www.whitehouse.senate.gov/news/release/sen-whitehouse-mep-aubry-lead-transatlantic-letter-calling-for-climate-talks-free-of-fossil-fuel-industry-interference

[6] Investor expectations on climate policy engagement disclosure have been articulated by the UN Principles for Responsible Investment, the Climate Action 100+ global collaborative stewardship program, and the investor led Responsible climate lobbying: The global standard. See, e.g., https://climate-lobbying.com/

[7] Guide for Responsible Corporate Engagement in Climate Policy, United Nations Global Compact, available at https://unglobalcompact.org/library/501