Media release

Shell commits to shedding light on emerging market lobbying

The Australasian Centre for Corporate Responsibility​ (ACCR) is commenting on the announcement by Shell plc that it will disclose information about its climate and energy lobbying in “5-10 emerging and developing markets that are significant for our strategy, before our 2025 AGM.”

The commitment from Shell comes following a shareholder resolution filed by KLP, Norway’s largest pension fund; Sampension, one of Denmark’s largest pension providers; and the Australasian Centre for Corporate Responsibility (ACCR), ahead of the company’s May 2024 AGM. It was filed with the assistance of UK-based responsible investment NGO ShareAction and several of its public supporters.

The resolution, which asked Shell to provide a global account of its material direct and indirect climate and energy-related lobbying, has now been withdrawn, following engagement between investors and the company.

Last month, ACCR published research highlighting how Shell is failing to disclose to investors its climate lobbying in emerging markets.

Nick Spooner, UK Company Strategy Lead, Australasian Centre for Corporate Responsibility said:

“This commitment is a major shift from Shell, which sees it move from disclosing nothing about its extensive lobbying activities in emerging markets, to acknowledging that better disclosure is warranted.

“Until now, investors in Shell have been flying completely blind. Nearly 60% of Shell’s fossil fuels production from 2024 to 2050 is expected to come from emerging markets, yet investors have had no insight into lobbying activities in these markets that are material to the company's forward business – including if lobbying by Shell and its industry associations is misaligned with the Paris goals and under-cutting Shell’s own decarbonisation strategy.

“By expanding its disclosures to include emerging markets Shell is taking an important first step to ensuring consistency between the company’s lobbying activity and its strategy.

“It is, however, just a first step. Investors need full transparency over Shell’s material lobbying in emerging markets, especially because of the company’s substantial LNG growth strategy, which is focused on these markets.

“ACCR’s research identifies multiple examples of undisclosed lobbying by Shell and its industry associations in emerging markets. A number of these industry associations are actively lobbying for policies that risk locking-in levels of fossil fuel demand that are misaligned with the Paris goals.

“In the context of Shell winding back its own climate targets and its Paris-misaligned projections for gas demand growth, especially in Asia, there remains a concern about how well Shell is positioning itself to thrive in the energy transition.”

Arild Skedsmo, Senior Analyst, Responsible Investments, KLP said:

“Influential companies should use their leverage in support of progressive government policies and be fully transparent in their lobbying wherever they operate. We see this as entirely aligned with the self-interest of companies serious about their role in the transition, and appreciate Shell’s renewed commitment to lead on this.”

Jacob Ehlerth Jørgensen, Head of ESG, Sampension said:

“We are fully committed to continue to work with both companies and civil society organisations to support the transition to a low carbon economy and welcome Shell’s commitment to expand on its lobbying disclosures which is a prerequisite for us as investors to assess the robustness of the company’s climate strategy.”


Shell has materiality criteria that would suggest its disclosures capture lobbying activities globally. However, this is not the case, as disclosures to date have not included emerging markets, where Shell projects the majority of demand growth and where ACCR’s analysis indicates much of Shell’s fossil fuels production is expected to come from. We expect Shell’s inclusion of some emerging markets in its disclosures will also be accompanied by a system overhaul that ensures proportionality.

ACCR has identified emerging markets where Shell’s advocacy activities, either on the supply or demand side,  could be material. We expect that the 5-10 countries that Shell will report on would be selected from the below list:


















South Africa



Trinidad and Tobago





About ShareAction

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