COP CO-OPTED?

How corruption and undue influence

threaten multilateral climate action
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COP Co-opted?
How Corruption and Undue Influence Threaten Multilateral Climate
Action

Authors: Louis Goddard, Florian Hollenbach, Michael Hornsby, Sam

Leon, David Szakonyi.

Contributors: Brice Böhmer, Jorge Valladares.

Acknowledgements: Gvantsa Gverdtsiteli, Anoukh de Soysa, Maíra

Martini.

Cover:

Every effort has been made to verify the accuracy of the information
contained in this report. All information was believed to be correct as
of October 2024. Nevertheless, Transparency International cannot
accept responsibility for the consequences of its use for other
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© 2024 Transparency International. Except where otherwise noted,

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 TABLE OF CONTENTS

Executive summary .................................................. 4 Smoke & Mirrors? Civil Society & Media
Engagement ............................................................ 26
Risks To COP Integrity .................................................... 5
The COP29 NGO Coalition ........................................... 26
Recommendations.......................................................... 7
Strategic PR blitz ........................................................... 28

Introduction ............................................................ 10
Conclusion ............................................................... 31
Methodology .................................................................12
Recommendations ....................................................... 32

Oligarchic Autocracy & Personal Enrichment ..... 13

ENDNOTES ............................................................... 35
Oil Wealth Feudalism ...................................................13

Organised Corruption?.................................................14

SOCAR’s problematic role in COP 29..................... 16

SOCAR and the Azerbaijani State ................................16

SOCAR and the COP 29 Presidency ............................17

SOCAR’s history of bribery and undisclosed payments

........................................................................................18

WHAT IS AT STAKE FOR AZERBAIJAN’S FOSSIL FUEL

INDUSTRY AT COP? ................................................. 20

Increased European Gas Demand ..............................21

Domestic Upstream Expansion...................................22

SOCAR’s Regional Expansion .......................................23

Azerbaijan’s Progress in Renewables .........................24

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TRANSPARENCY INTERNATIONAL

EXECUTIVE SUMMARY
Undue corporate influence at UN climate conferences can
undermine climate policy and action. These risks are especially
apparent when the host nations of the Conference of the Parties
(COP) are fossil fuel exporters with corrupt and autocratic
governments.

The world faces an unprecedented threat from oil and gas deals for the state oil company, with the
climate change caused by greenhouse gas COP 28 president even using some COP-related
emissions from more than a century of reliance on meetings to advance company deals.4 And despite
fossil fuels in energy, transport and industrial agreement on the need for a global energy
systems. transition, political and industry leaders around the
world have clearly signalled their intention to
The enormity of the challenge requires coordinated,
continue exploiting new fossil fuel reserves.5
ambitious and evidence-informed action to reduce
greenhouse gas emissions and phase out fossil This report finds that in its current form, COP, as the
fuels. Global warming must not surpass a global main global forum for setting the climate policy
average of 1.5 degrees Celsius above pre-industrial agenda, is at risk of being undermined by undue
levels, in order to protect ecosystems and human corporate influence and fossil fuel industry capture.
security.1 Corruption and kleptocracy, too, threaten the
integrity of climate conferences, including the
Every year, world leaders and national delegations,
upcoming COP 29 in Baku, Azerbaijan, in November
together with scientists, activists, and trade, finance
2024.
and industry representatives, gather at the
international Conference of the Parties (COP) to the A range of stakeholders have raised concerns about
United Nations Framework Convention on Climate Azerbaijan’s selection as host of COP 296, and in
Change (UNFCCC) to report on their progress and September 2024, the Financial Times reported that
negotiate further measures to prevent and respond some climate negotiators from the EU and western
to human-caused climate change. country delegations were already frustrated that the
COP 29 Presidency appears reluctant to prioritise
The COP host country rotates annually through five
decarbonisation in the climate talks.7 In October,
UN regions. In addition to providing the
Urgewald and CCE Bankwatch Network published a
infrastructure for the event, the host country
report detailing Azerbaijan's oil and gas expansion
government typically proposes a president, who
plans and raising concerns about whose interests
once nominated is responsible for “raising ambition
will be heard at COP 29.8
to tackle climate change internationally” and liaising
with country delegations to ensure successful Indeed, this report finds that through its
negotiations during the COP.2 organisation of COP 29, Azerbaijan, with its
autocratic government, large fossil fuels sector, and
At COP 28, hosted by the United Arab Emirates
severe levels of public sector corruption, clearly
(UAE) in 2023, all Parties committed to transition
illustrates several risks to the integrity of UN climate
away from fossil fuels in energy systems by 2050.3
conferences.9
At the same time, however, the UAE appears to have
used its COP presidency to sign an avalanche of new

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 COP CO-OPTED?

It is important to highlight that these risks are not on their close relations with the autocratic regime of
unique to Azerbaijan or COP 29. The hosts of COPs President Ilham Aliyev for market position (see
28, 29 and 30 – the UAE, Azerbaijan, and Brazil — chapters 1, 3). Fossil fuel lobbyists, already heavily
are all significant fossil fuels exporters with state- represented at recent UNFCCC climate conferences,
owned oil companies. These three countries have may consider the Baku summit a prime opportunity
formed a “Troika” which claims to be committed to to secure a place for continued fossil fuel expansion
the Paris Agreement target of keeping global in the multilateral climate agenda.
warming below 1.5 degrees Celsius.10 But evidence
Additionally, the UNFCCC does not require host
from Dubai, and this report’s analysis of the
countries to declare the interests of public officials
upcoming COP 29 in Baku, suggest that some
involved in organising COP, or for host countries to
members of this Troika can use the COP events as
adopt transparency practices that can reveal
diplomatic showcases to support their domestic oil
potential or actual conflicts of interest of the
industries, sign new fossil fuel deals, and sanitise
president and conference organisers. Azerbaijan
their records of human rights abuses and
does not publish information about the assets and
environmental harms.
liabilities of public officials and their families and
These risks extend beyond the Troika, and even has high levels of public sector corruption.11 Political
beyond the fossil fuels industry, as other industries and economic power is extremely concentrated,
may seek to leverage their influence over COP hosts including in the energy and construction sectors
to secure unduly favourable outcomes that impede (see chapter 1). Because of Azerbaijan’s climate
climate action. push around COP 29, these sectors are likely to
receive additional investment and potentially
The UNFCCC, its Parties, and the global climate
international funding for renewables infrastructure.
community must urgently act to reform some key
Members of the COP29 Organising Committee with
aspects of arrangements for COP to prevent private
interests in the energy sector have already been
interests from co-opting the climate conferences
accused of conflicts of interest and corrupt public
and inadvertently enabling corruption and
procurement (see pages 14, 18). There are currently
authoritarianism.
few obstacles to attempts to influence or capture
new investments.
RISKS TO COP INTEGRITY Risk 2: The COPs can become a forum for fossil
fuel diplomacy and deal-making
Risk 1: COP negotiations can be unduly
The UNFCCC currently lacks robust guardrails
influenced and captured by corporate interests,
against corporate and fossil fuel influence in the
including fossil fuels companies
host country’s organisation of COP. As noted above,
There are currently no limits or transparency several current and former executives and
requirements on corporate sponsorship at COPs, representatives of SOCAR have prominent roles in
and corporate guests can participate in national the organisation of COP 29 (see page 17). This
delegations without having to declare their interests follows the UAE’s unprecedented abuse of the COP
(see page 11-12). This gives them enhanced access 28 Presidency revealed by Global Witness, in which
to decision-makers. Already apparent at previous the Abu Dhabi National Oil Company pursued
COPs, the lack of guard rails against corporate US$100 billion worth of deals.12
influence is especially problematic when hosts like
While Azerbaijan holds the COP Presidency, SOCAR
the UAE and Azerbaijan have powerful state-owned
is pursuing a strategy of regional expansion and
oil companies.
collaborating with international oil companies to
Azerbaijan’s state oil company, SOCAR, is closely develop new exploration and extraction projects.
connected to preparations for COP 29. The COP 29 SOCAR executives have already been seen mixing
president-designate is a former senior executive at matters related to COP 29 with new business
the company. SOCAR’s president is a member of the agreements to explore and develop fossil fuels
COP29 Organising Committee, and the CEO of COP production with European energy companies (see
29 sits on SOCAR’s supervisory board. The chair of Chapter 3). In the lead-up to the summit, SOCAR and
SOCAR’s supervisory board is also involved in its most important international partner, BP, have
planning COP 29 (see page 17). been publicly celebrating their lucrative and long-
running collaboration and signing new deals (see
Moreover, several international oil companies have
page 23).
significant business interests in Azerbaijan and rely

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TRANSPARENCY INTERNATIONAL

Risk 3: The organisation of COPs can become an designed to favour fossil fuel incumbents (see page
opportunity for corrupt and kleptocratic 25-26).
personal enrichment
Media and civil society play a vital role in detecting
There are no specific good governance and calling out attempts at greenwashing. Current
requirements for countries registering their interest COP hosting agreements seek to ensure the
in hosting UN climate conferences, so countries with participation of accredited media and civil society in
autocratic and corrupt governments can easily take in the official conference venue. However, there are
the reins. Several of the COP 29 “Green Zone currently no criteria for host governments to
Partners” have clear or alleged links to the first guarantee the right to freedom of expression
family of Azerbaijan (see page 15), providing these outside of the conference premises.
companies with potentially lucrative marketing
In Azerbaijan, independent media and civil society
opportunities and a platform to present unproven
are highly repressed.14 The government has silenced
green credentials on the world stage.
critical civil society voices and reportedly holds over
300 political prisoners.15 Meanwhile, however, the
Ahead of COP 29, investigative journalists have
COP 29 organisers have established a “COP29 NGO
revealed that Azerbaijan awarded a multi-million
Coalition,” which appears to be an example of the
dollar no-bid contract for COP 29 guest
Aliyev regime’s tactic of using government-approved
accommodation to a business owned by the former
organisations to create an impression of civil society
son-in-law of President Aliyev (see page 15). As
participation (see page 26-28) and delegitimise
noted above, no transparency is required around
criticism.
corporate sponsorship of COPs and such practices
can lead to higher costs for participants, resulting in A lack of independent oversight by media and civil
reduced participation from groups with limited society organisations exacerbates the risk that
resources, including civil society and Indigenous governments use COP to greenwash energy projects
peoples. and whitewash their human rights records.

Risk 4: Hosting COP can become an A complex picture

opportunity for greenwashing
Azerbaijan’s organisation of COP 29 illustrates how
In theory, the COP president is a neutral convener of
several of these risks can interact. For example, an
a forum for negotiations. Yet, host countries often
industrial conglomerate linked to the family of the
take the summit as an opportunity to promote their
country’s president might be awarded potentially
green credentials and advance their own vision for
lucrative partner status at the conference (see page
the future on the world stage. Where commitment
15). This can give the company greater access to,
to solving the climate crisis and upholding human
and influence over, climate negotiations, potentially
rights are weak, this can create a contradiction.
contributing to watered-down agreements and
There are no readily enforceable checks and
policies. If the conglomerate has interests in the
balances on how the host may use the COP brand to
fossil fuels sector, the international marketing and
promote its own agenda, which might include false
networking opportunities created by the climate
solutions that can distract from ambitious climate
conference may lead to new fossil fuel industry
policy and action and move away from science-
deals for the company.
backed targets.

In keeping with the fossil fuel industry messaging At the same time, thanks to its government
playbook described by Influence Map13, the connections, the conglomerate's subsidiaries may
Azerbaijani government claims that fossil fuel be first in line to benefit from investment in
expansion is compatible with multilateral climate renewable energy infrastructure, further
goals. The COP 29 organisers are paying a public entrenching the role of fossil fuel incumbents and
relations firm almost US$5 million to undertake a weakening market competition that can accelerate
blitz of strategic PR activities that help mainstream the transition. When all this happens in a vacuum of
this message (see page 29). At the same time, upon independent, local oversight, the potential for
closer inspection, one of Azerbaijan’s flagship green corrupt activity and undue corporate influence
energy projects seems designed to boost the increases.
country’s oil and gas exports, while plans for long-
term roll-out of offshore wind power appear

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 COP CO-OPTED?

COP 29: Know Before You Go RECOMMENDATIONS

The entire COP community should be cognisant of
The UNFCCC has lacked adequate integrity rules for
how the interests of Azerbaijan’s fossil fuels
too long. Meanwhile, the opaque influence of fossil-
industry and its key players may be influencing the
fuel interests over governments is undermining
actions and positions of the COP 29 Presidency
progress towards the climate goals of the Paris
and Azerbaijan’s role as host.
Agreement.
1. Organised by oil men. Azerbaijan’s state oil
The case of Azerbaijan, as evidenced by this report,
company, SOCAR, is heavily involved in the
illustrates how the lack of guardrails can allow COP
preparations for COP 29. The COP 29 president-
to be unduly influenced and captured by corporate
designate is a former senior executive at the
interests, and can become an opportunity for
company. SOCAR’s president sits on the COP29
greenwashing and corruption.
Organising Committee, and the CEO of COP 29 sits
on SOCAR’s supervisory board. The chair of After COP 26, where some observers reported
SOCAR’s supervisory board is also involved in obstacles to participation, the UNFCCC Secretariat
planning COP 29 (see page 17). launched a process around observer engagement.
Since last year, COP delegates are required to
2. Deals on the line. COP 29 is at risk of becoming
declare their professional affiliation when they
another forum for fossil fuel diplomacy and deal-
register for COP online. However, the process fall
making. With SOCAR currently pursuing a strategy
short as disclosure remains limited and voluntary.
of regional fossil fuels expansion, senior SOCAR
Moreover, delegates can keep their affiliation
figures have been seen mixing COP business with
hidden during negotiations.
deals for the national oil company.
The UNFCCC Secretariat can do more. The
3. Reputational laundry. A slick multi-million-
Secretariat has a special responsibility to live up to
dollar PR campaign for COP 29 is also supporting
its mission of “protecting the integrity of the UN
the Aliyev regime’s arguments that continued fossil
Framework Convention on Climate Change, the
fuel industry expansion is a necessary part of the
Paris Agreement and their related goals”.16 It should
green energy transition. In parallel, and while the
guarantee unrestricted civil society participation and
Aliyev regime silences critical civil society voices,
implement guardrails that mitigate risks of future
the organisers have established an “NGO
COPs being co-opted to serve private and fossil fuels
Coalition,” which includes organisations with links
interests.
to the Azerbaijan government and track records of
uncritical support for the Aliyev regime (see The Secretariat should prevent the COP Presidency
Chapter 4). from being used to advance the presidency’s own
(fossil fuel industry) interests, using its mandate
4. Inside Games. Some members of the COP29
from existing processes including the Code of Ethics
Organising Committee have been involved in high-
for Elected and Appointed Officers, the Host Country
profile corruption scandals. There are already clear
Agreement (HCA) signed with each COP President,
signs that COP 29 is being used to promote the
the handbook on hosting a COP and the Secretariat
business interests of the first family of Azerbaijan
guidelines for partnership.
(see page 15). This includes a major contract for
COP 29 guest accommodation. In addition, State Parties should commit to actively
tackling issues related to conflicts of interest and
5. Green veneer. On closer inspection, one of
undue influence. They should launch a formal
Azerbaijan’s flagship green energy projects seems
process to enhance stakeholder engagement and
designed to boost the country’s oil and gas
adopt ambitious instruments to mitigate risks of
exports, while long-term plans for the roll-out of
undue influence. They should put in place strong
offshore wind power seem designed to further
safeguards to manage conflicts of interest in the
entrench the position of fossil fuel incumbents (see
elaboration of national positions as well as in the
page 25-26).
international negotiations.

Two recent announcements by the COP 30 host

country, Brazil, seem to indicate recognition of the
need for greater integrity for successful climate
action and willingness to act. We hope that the
announced “global ethical stocktaking”17 and the

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TRANSPARENCY INTERNATIONAL

G20 proposal that “anti-corruption be at the centre before, during and after UNFCCC sessions
of policies to combat climate change”18 can address and mandated events. This should include
the findings of this report and begin the immunity of observer organisations’
implementation of the recommendations listed representatives and other persons from
below. legal process in respect of words spoken or
written and any act performed by them,
Integrity over the choice of the host country
within and outside conference premises.
Current practice does not prevent unsuitable
governments from becoming the hosts of the most • The host country should engage in HCA
important global gathering on climate change and discussions in a transparent way and make
using the COP Presidency to privilege national or the draft HCA available for feedback.
specific industry interests over the common good. • In line with the June 2023 guidance from
The COP should follow a more robust process to the Subsidiary Body for Implementation
select host countries: (SBI),20 HCAs should be published promptly
• In addition to the current logistical, on the UNFCCC website as soon as they are
technical, and financial considerations, the signed.
Secretariat should assess and report to the
• HCAs should make the UNFCCC
Bureau on whether the prospective host
Secretariat’s approval of partners
country provides a conducive environment
compulsory. Specifically, HCAs should
for all participants, particularly
follow the UNFCCC “process for due
representatives from observer
diligence and criteria for selection of a
organisations, to exercise their human
partner,” and include similar provisions to
rights without fear of intimidation and
prevent sponsorship by entities “whose
repercussions, as well as guarantee
products, services or operations may
reasonable costs for participation, thus
negatively affect the objectives, activities or
allowing that concerned groups with
reputation of the secretariat, including but
limited resources have equal access to
not limited to entities whose core products
negotiations;
or core related services include fossil
• The COP should only consider expressions fuels.”21
of interest that have been vetted by the
• Host deals involving corporations and
Bureau of the COP, after review and
organisations granted Green Zone partner
confirmation by the Secretariat that the
or exhibitor status must be published on
proposal of the government demonstrates
the UNFCCC website so that financial
commitment to the goals of the Convention
relationships are open to public scrutiny.
and the Paris Agreement, the purposes and
principles of the Charter of the United • The UNFCCC must establish clear guidelines
Nations, and international human rights governing the use of the COP brand in host
law before, during and after UNFCCC country initiatives and diplomacy to prevent
sessions and mandated events; misuse that could promote endorsement of
solutions serving fossil fuel interests or
• These requirements should be reflected in
policies that contradict the goals of the
the handbook on hosting a COP.
UNFCCC and the Paris Agreement.
Transparency around COP preparations and
Accountability of the COP Presidency
hosting arrangements
The Presidency must be impartial, even if the
The host country must abide by the UNFCCC’
appointing government has interests that conflict
process for due diligence and criteria19 for selection
with science-aligned guidance for delivering the 1.5-
of corporate partners. It should only allow
2 degrees Celsius goal of the Paris Agreement. To
sponsorships from entities that demonstrate
preserve this impartiality, the Bureau of the
commitment to the United Nations Global Compact
Conference of the Parties (COP) must substantially
and the United Nations Guiding Principles on
review the Code of Ethics for Elected and Appointed
Business and Human Rights.
Officers. Particular attention should be given to
• HCAs must include a commitment to Article 14, to include the following:
uphold international human rights law

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 COP CO-OPTED?

• the obligation to disclose any situations or • The COP should establish a conflict of
relationships, financial or otherwise, that interest policy that clearly defines a conflict
might be perceived as affecting the of interest, sets out disclosure
objectivity and impartiality of the requirements, and details how conflicts will
presidency in an interest disclosure form be managed. It should ensure that all COP
that must be made publicly available on the participants, including delegates, observers,
website of the UNFCCC Secretariat; and exhibitors, formally agree to abide by
this policy as a condition of their
• the incompatibility of the position of
participation.
president with any role (remunerated or
not) and any holding financial or vested • All delegations should adhere to the highest
interests in an entity whose core products standards of transparency regarding whom
or core related products, services or they invite in their delegations and
operations may negatively affect the meetings with lobbyists in preparation for
objectives, activities or reputation of the and during COP.
UNFCCC, including but not limited to fossil
fuels; Business responsible engagement

All private sector entities participating in the COP as

• the public disclosure of all formal and
part of government delegations and observer
informal meetings held in connection to the
organisations must adhere to minimum standards
role of the presidency, with an indication of
for responsible political engagement. In line with the
the topics addressed and attendees;
Global Standard on Responsible Climate lobbying22,
• the establishment of a clearly outlined organisations should publicly disclose:
process to deal with arising conflicts of
• the policy issues or regulatory acts related
interest and non-adherence to ethical rules;
to their lobbying activities, with an
• effective rules to enforce the replacement indication of their positions regarding the
of the president when he or she violates Paris Agreement goal of restricting global
ethical duties. warming to 1.5 degrees Celsius above pre-
industrial levels;
Transparency and accountability around COP
participation • their expenditures on lobbying,
sponsorships, and other political
The COP is an international UN space. All engagement activities;
information about whom the participants represent,
• the links to any public policy statements
and their reasons for participation, should be made
and research sent to public decision-
publicly available.
makers, as well as to all transparency
registers in which the entity is registered;
• The UNFCCC Secretariat should improve
and enforce transparency requirements for • the list of individuals in their senior
the registration of COP participants, so that management, board or in advisory
their most relevant affiliation is positions who have previously or currently
compulsorily declared and publicly released hold, or are otherwise seconded to, a
well ahead of the COP. This information position in government on climate matters
should also be made visible during the COP. or a government delegation to COP.
• All COP organisers and delegation
attendees should be required to declare
any significant financial interests in,
sponsorship by, or control over entities
whose core products or core-related
products, services or operations may
negatively affect the objectives, activities or
reputation of the UNFCCC, including but not
limited to fossil fuels.

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TRANSPARENCY INTERNATIONAL

INTRODUCTION

“As the head of a country rich in fossil fuels, of extensively about corruption and weak
course, we will defend the right of these countries to accountability in Azerbaijan’s oil and gas industry. In
continue investments and production because the July 2023, Ibadoglu was arrested on charges of
world needs it,” Azerbaijan’s President llham Aliyev religious extremism and use of counterfeit money.
said in April 2024 at the Berlin Petersburg Climate Most observers view the charges as politically
Dialogue, an annual event hosted by Germany to lay fabricated to silence his criticism of the regime.29
the groundwork for upcoming climate
negotiations.23
As the head of a country rich
Aliyev’s remarks would have sorely disappointed any
of the assembled delegates who hoped that the
in fossil fuels, of course, we
leader of one of the world’s most fossil-fuels will defend the right of these
dependent economies would emerge as a bold new countries to continue
climate champion on the world stage.24
investments and production.
In his remarks, Aliyev called oil and gas deposits “a
gift from God”, for which Azerbaijan must not be President Ilham Aliyev of Azerbaijan
judged. Instead, the Azerbaijani government, which
he and his father have led since 1993, “must be
judged based on how we use these reserves for the
development of the country, to reduce poverty and To maintain its grip on power, the Aliyev regime
unemployment, and on what our targets are with has also relied on corruption overseas. Investigative
respect to the green agenda.”25 journalists, prosecutors and civil society
organisations have revealed how revenues from
Critics of the Aliyev regime have repeatedly Azerbaijan’s fossil fuels production have been used
complained that corruption and undue influence to bribe parliamentarians in Europe – and allegedly
have concentrated Azerbaijan’s oil wealth in the in the US – to whitewash the country’s elections and
hands of the ruling elite. Azerbaijan scores just 23 human rights records.30
out of a possible 100 on Transparency
International’s Corruption Perceptions Index, Similarly, Azerbaijan’s “targets with respect to the
indicating widespread and deeply entrenched green agenda” may not be as impressive as Aliyev
public-sector corruption.26 would have liked his audience to believe. Evidence
presented in this report suggests that the country’s
Azerbaijani citizens enjoy few political rights and civil powerful state oil company, SOCAR, is playing a
liberties.27 Human rights activists say there are over central role in the organisation of the conference at
300 political prisoners in Azerbaijan.28 Among them the same time as it pursues a strategy of expansion,
is Dr. Gubad Ibadoglu, a leading human rights facilitated by international oil companies and
defender and economist who has written regional partners. In the view of some analysts,

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 COP CO-OPTED?

Azerbaijan’s renewable energy projects serve influence and the known risks of corruption,
primarily to reduce domestic gas consumption, censorship and oppression in Azerbaijan.
allowing SOCAR to increase lucrative exports to the
The picture that emerges suggests that COP 29 is at
European Union.31
risk of being co-opted to further the strategic and
Meanwhile, Azerbaijan has been accused of financial interests of its host government. The COP
“greenwashing” with its renewable energy projects.32 itself could become a greenwashing exercise and
Overall, the country’s actions with respect to climate lose the trust of some Parties, as well as the broader
change have been rated ’critically insufficient’ by the climate community.
non-profit Climate Action Tracker project.33
The COP 29 organisers did not respond to the
As host and president of COP 29, Azerbaijan is authors’ request for comment on the findings of this
responsible for furthering the mission of the report.
UNFCCC to accelerate international action to reduce
greenhouse gas emissions and keep the Paris
Agreement target of 1.5 degrees Celsius warming in
sight. It is up to the COP Presidency to develop “a Conflicting Interests at COPs
vision for the best possible outcome of the
In the context of the UNFCCC, a conflict of interest
meeting.”34
occurs where an individual or organisation
What does it mean for the integrity of this process involved in the negotiation process has competing
when the negotiations for climate action are in the allegiances that may impact their ability to act in
hands of a country whose government has declared support of the UNFCCC’s guiding objective: to
it will continue to defend the right of countries to stabilise greenhouse gas concentrations in the
continue with new fossil fuels investments and atmosphere "at a level that would prevent
production? dangerous anthropogenic (human-induced)
interference with the climate system."35
And what does it mean when this statement comes
from the president of a country without checks and Civil society groups have long been pushing the
balances on power, where dissenting voices are UNFCCC to take a position on conflicts of interests,
silenced and fossil fuel revenues used to fund largely in response to the vast numbers of fossil
transnational corruption – all with the support of fuel lobbyists that have attended previous COPs
international oil majors? and the risks they pose to the process.36

Each year, the climate NGO Global Witness pores

What risks does this create for the integrity of the
over the provisional delegates list after its release
COP process, and what can the international
during COP, reviewing corporate affiliations to
climate, anti-corruption, diplomatic and
determine which interests a specific delegate may
development communities do to counteract these
be advocating for and to identify fossil fuel
risks, now and in the future?
lobbyists. The UNFCCC could pre-empt this activity
With evidence suggesting that Azerbaijan is by requiring all attendees to disclose any conflicts
following similar tactics to COP 28 host the United of interest arising from their employment or
Arab Emirates and using the COP Presidency as a business dealings.
platform for fossil fuel diplomacy, are we seeing the
Absent such measures, the number of fossil fuel
development of a playbook for fossil fuels exporters
lobbyists in attendance rose to an all- time high of
that could undermine COPs for many years to come,
2,456 at COP28 in Dubai in 2023.37 Nonetheless,
potentially including COP 30 in Brazil?
the UNFCCC has not yet implemented a clear and
This report seeks to answer these questions to effective policy regarding participants’ conflicts of
support the possibility of bold, evidence-based interest.
multilateral climate action across the UNFCCC
Starting last year, all delegates who attend a COP –
agenda.
whether at the invitation of a Party or observer –
To do so, researchers analysed the available are asked to declare their relationship to the
information about Azerbaijan’s oil industry and the government, international organisation, UN
country’s activities as host of COP 29 in the lead-up agency, NGO or other entity that invited them.
to the November summit, and set this against both However, delegates have the possibility not to
the COP’s known vulnerabilities to undue industry disclose their relationship and declare simply
“Other” or “Guest.” Analysing the list of participants

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TRANSPARENCY INTERNATIONAL

at COP 28 published by UNFCCC38, we found that bono program The Bright Initiative, supporting
more than 16 per cent of all attendees chose not impact driven projects and organisations.
to disclose their relationship – more than 90 per
cent of those being on a Party badge. Another 19 Oil deals and energy projects
per cent indicated “Other” and a further 23 per
cent declared themselves simply as “Guest.” All To analyse SOCAR's current activities in Azerbaijan
told, therefore, more than 58 per cent of COP and internationally, we relied on the company's
delegates did not elaborate on their relationship to annual reports, accounts from the oil and gas trade
the organisation that invited them. This does not press, a report on the Azerbaijani upstream oil and
necessarily mean that those participants have a gas sector from the consultancy Wood Mackenzie
conflict of interest, but demonstrates a troubling and information from the NGO Crude
lack of transparency, which limits access to Accountability.
important information for watchdog groups like
For information on current and future renewable
media and civil society.
energy projects, we used data from Global Energy
Monitor's Global Solar Power Tracker and Global
Wind Power Tracker, along with TransitionZero's TZ-
METHODOLOGY SAM dataset.

Data on flights taken by the SOCAR corporate jet

This report was compiled in September and October
was obtained from ADS-B Exchange, a community-
2024, based primarily on a qualitative review of
run project pooling ADS-B data from volunteers.
public sources available at the time. These sources
including books, articles, online databased and
reports are cited throughout. For three areas of the Lobbying and PR
report, more complex methodologies and/or data
sources were used, as described below. Our analysis of Teneo's contract with the COP29
Operations Company is based on filings under the
US Foreign Agents Registration Act (FARA), published
Conflicts of interest by the US Department of Justice as well as
background reporting on the members of Teneo’s
We used public sources to obtain lists of individuals
team working on the contract and their outreach to
linked to the organisation of COP 29:
journalists.
• the COP29 Organising Committee
• the COP29 International Advisory
Committee
• the COP29 Presidency Team
• Azerbaijan's delegations to COP 28 in the
UAE and to the 2024 UNFCCC intersessional
meeting in Bonn

We also compiled a partial list of members of the

COP29 NGO Coalition, based on several published
screenshots of virtual meetings.

Having compiled these lists, we categorised the

individuals by their primary affiliation (business,
politics, government or civil society) and added links
to their social media profiles and/or Wikipedia
entries where available.

We then programmatically searched for information

on each individual using public sources – primarily
the Azerbaijani and international press – and
compiled the results into a central database,
recording links between individuals and companies
as they emerged. In part, we relied on the data
collection tools of Bright Data, provided by the pro-

12
 COP CO-OPTED?

OLIGARCHIC AUTOCRACY &

PERSONAL ENRICHMENT

Although the UNFCCC conducts a factfinding Rather than liberalising, the current regime seems
mission to prospective host countries to to be further entrenching itself in power. The
examine logistical, technical and financial current president, Ilham Aliyev, succeeded his father
readiness for the conference, neither the health in power in 2003. Initially barred from serving more
of democratic governance nor commitment to than two terms, Aliyev won a controversial
goals of the conference appear to be assessed. referendum in 2009 that scrapped constitutional
There are no specific safeguards against corrupt term limits, concentrated power in the executive
and kleptocratic host governments using the branch and was rushed through without proper
conference for deal-making or self-enrichment. parliamentary or public discussion.42 After calling
The UNFCCC gives the host country advice on snap elections a year early, Aliyev was re-elected in
businesses that apply to become corporate February 2024 for a fifth consecutive term, this time
partners, but currently does not approve them with 92 per cent of the votes. Over the last year, the
or set standards for due diligence by the host. regime has further cracked down on independent
While the COP Presidency is expected to liaise media and restricted the activities of independent
closely with the UNFCCC Secretariat on matters political parties.43
regarding formal negotiations in the official UN
In addition to institutional hardening of the regime,
“Blue Zone,” host countries are largely free to
Aliyev has continued to strengthen his hold on
propose their own initiatives for voluntary
power by rewarding loyalists and filling government
adoption by governments. Hosts also organise
positions with allies. According to the 2024
and control access to the “Green Zone” adjacent
Bertelsmann Transformation Index Report for
to the conference.
Azerbaijan, “Over the past two years, the president
Azerbaijan scores just 23 out of 100 on has consistently replaced long-standing senior
Transparency International’s Corruption Perceptions officials with young and loyal cadres, many of whom
Index, indicating widespread and deeply entrenched have forged their careers in companies associated
public-sector corruption.39 Azerbaijan’s regime has with the ruling family.”44
long been highly autocratic, with no signs of political
liberalisation. Freedom House scores Azerbaijan
with seven out of a possible 100 points.40 The OIL WEALTH FEUDALISM
Swedish Varieties of Democracy Institute ranks
Azerbaijan in the bottom 15 per cent of its liberal As the head of an autocratic state, Aliyev receives
democracy index, with a score similar to Russia and direct political benefits from his country’s resource
South Sudan. And while the country holds elections, wealth, even before considering potential personal
these are neither free nor fair, making Azerbaijan an income gains. Vast natural resource revenues likely
”electoral autocracy”. 41 increase the stability of the non-democratic regime,
both by providing material benefits to regime

13
TRANSPARENCY INTERNATIONAL

insiders and by financing government investment

and spending in the Azerbaijani economy.
ORGANISED CORRUPTION?
In an entrenched oligarchic autocracy, such as Investigations by journalists including Abzas Media,
Azerbaijan, much of the economy is based on an Azerbaijani media outlet whose editors are
personal relations to the regime. The rule of law and currently in exile following a crackdown by
property rights exist only as far as the regime authorities,51 allege that multiple members of the
allows.45 The families of the president and first lady
COP29 Organising Committee have been involved in
(who is also the vice president) control vast amounts
corrupt government procurement. An investigation
of wealth, including PASHA Holding, a conglomerate
published in March alleged that Balababa Rzayev,
of firms offering construction, financial, insurance,
president of the state-owned energy company
and many other services. In 2012, the Organized
Crime and Corruption Reporting Project’s (OCCRP) Azerenerji and a member of the committee,
named Aliyev “Person of the Year” based on “how awarded contracts for new renewable energy
his family had taken large shares in lucrative projects and electric grid upgrades in the Nagorno-
industries including the telecom, minerals and Karabakh region to companies linked to his family
construction industries often through government- members.52
related deals.”46 Leaked US State Department cables
Many agricultural contracts in the Karabakh region
from 2010 described Azerbaijan as “run in a manner
went to firms directly connected to the President’s
similar to the feudalism found in Europe during the
family through PASHA Holding. Ali Naghiyev, head of
Middle Ages: a handful of well-connected families
the president’s security services and a member of
control certain geographic areas, as well as certain
the COP29 Organising Committee was another
sectors of the economy.”47 Although construction
beneficiary. A firm with significant overlap in
projects in Baku can be difficult to finish due to
ownership to his family’s firms was awarded
“government-imposed delays”, firms connected to
contracts worth US$12 million.53 In a previous
the regime are unlikely to suffer such setbacks, the
position, Naghieyev was deputy chief of the Anti-
diplomats reported.48 Since these comments were
Corruption General Directorate, yet the family was a
made, Azerbaijan’s score in Transparency
likely beneficiary of the Azerbaijan Laundromat
International’s Corruption Perception Index (CPI) has
bribery and money laundering operation, and his
remained effectively unchanged.49
sons hold an offshore real estate empire.54
The tightly woven connections between politics,
In a separate investigation, Abzas Media showed
natural resource exploitation, and businesses in
that firms connected to Yalchin Rafiyev, deputy
Azerbaijan fundamentally threaten the integrity and
foreign minister of Azerbaijan, and now lead
success of COP 29. In a country where little happens
negotiator of COP 29, have won government
outside the regime’s purview, it is not surprising that
contracts in Karabakh and elsewhere, while also
many members of the COP29 Organising
violating environmental rules by illegally removing
Committee are directly linked to the regime. And
trees.55
many have personal interests that may be in direct
opposition to the goals of the UNFCCC. These Another member of the organising committee is
tensions between public duty and private interests Kamaladdin Heydarov, whose family rivals the
create direct conflicts of interest. president’s family in wealth and power. Heydarov
Such conflicts are extremely difficult to detect in ran Azerbaijan’s customs service, which has long
Azerbaijan, because the government does not been dogged by allegations of corruption and, after
publish information about the assets and liabilities picking his own successor, became minister for
of public officials and their families, or information emergency situations, a department with an
about the beneficial owners of legal entities.50 unusually broad remit.56 His family's empire
Nonetheless, intrepid investigative journalists, many “range[s] from fruit juice production to real estate
of whom have faced imprisonment, abuse or exile, development” and includes firms closely tied to
have uncovered questionable deals involving regime
PASHA Holding.57
figures, many of whom are now part of COP 29.
These instances of alleged personal enrichment of
four high-profile members of the COP29 Organising
Committee and Presidency Team are likely only the
tip of the iceberg and make clear that the personal
interests of government members often come first

14
 COP CO-OPTED?

in Azerbaijan. Members of the Aliyev regime may Another Green Zone Partner is Silkway West
well use their influence at COP to push for positions Airlines, an air cargo company previously linked to
and deals from which they will personally gain. the Aliyev family, and which is among a group of
Based on the information available, (see below) it companies that “have taken over large parts of
appears that the organisation of COP 29 is already Azerbaijan’s aviation sector,” according to
being used to promote businesses connected to investigative journalists.64
Azerbaijan’s first family and other regime insiders.
Partner status at COP 29 presents the companies
with a valuable marketing platform. But a large
international event like COP creates a variety of
other ways to benefit those close to the Aliyev
Green Partners? family. Up to 5,000 COP 29 guests will reportedly
By mid-October, eight companies had been stay at a Baku seaside resort owned by Emin
announced as COP 29 “Green Zone Partners,” Agalarov, the former son-in-law of President Aliyev,
sponsors of the public-access space near the Blue and the son of Aras Agalarov, a billionaire
Zone, where the official climate summit takes Azerbaijani real estate developer.65 The no-bid
place.58 contract with the State Housing Development
Agency is worth 9 million Manats (approximately
The partners included SOCAR Green, a subsidiary US$5.3 million).66 Agalarov announced the contract
of the state-owned oil company established by at an investment forum at his resort attended by
presidential decree a few weeks after Azerbaijan three members of the COP29 Organising
was announced as COP 29 president in December Committee responsible for the economy, urban
2023.59 According to media reports, the capital planning and tourism in Azerbaijan.67
assigned to the new renewables-focused
subsidiary is US$16.5 million, or approximately The COP Presidency should represent a diversity of
1.34 per cent of SOCAR’s 2023 net profits.60 perspectives reflecting broader UNFCCC community.
If it is dominated by regime loyalists or a few
COP 29’s “Impact Partner” was announced as
business concerns, narrow self-interest can take
PASHA Holdings, a vast Azerbaijani conglomerate
precedence.
spanning finance, construction, real estate,
hospitality and retail. PASHA Holdings is owned In a context where these interests are completely
and controlled by the family of Azerbaijan’s first entangled with the fossil fuels industry, that risk
lady and vice president, Mehriban Aliyeva. It is not becomes potentially catastrophic for a climate
the first time the company has benefited from its summit.
close government ties. Four representatives of
PASHA Holdings and Pasha Bank joined
Azerbaijan’s official government delegation to COP
28 in Dubai.61

The same announcement revealed that another

large Azerbaijani holding company, Azersun
Holding, will be the “Sustainable Growth Partner”
of COP 29. Azersun’s companies operate across
retail, construction, food, sports and logistics. This
conglomerate is also allegedly linked to
Azerbaijan’s first family. In 2013, the Offshore
Leaks investigation by the International
Consortium of Investigative Journalists (ICIJ) and
partners revealed that Hassan Gozal, the brother
of Azersun Holdings founder and Chairperson
Abdolbari Gozal, was listed as the director of three
offshore companies established in the British
Virgin Islands for the daughters of President Ilham
Aliyev.62 Eight Azersun Holdings representatives,
including Abdolbari Gozal, travelled to COP 28 in
the Azerbaijan government delegation.63

15
TRANSPARENCY INTERNATIONAL

SOCAR’S PROBLEMATIC ROLE

IN COP 29

Most fossil fuel lobbyists tend to attend COP as

part of trade associations that are formally
registered as “observer” organisations. Members
SOCAR AND THE AZERBAIJANI STATE
of government delegations enjoy much greater
It is difficult to overstate the importance of SOCAR
access as governments themselves are Parties to
both to Azerbaijan’s oil and gas industry and to the
the UNFCCC. National oil companies are often
country as a whole. In 2023, the company made just
considered parts of government, and companies
over US$50 billion in revenue, compared to
like the State Oil Company of the Republic of
Azerbaijan’s total gross domestic product (GDP) of
Azerbaijan (SOCAR) can in theory have much
US$72 billion, with the vast majority coming from oil
greater influence over the negotiations. Fossil
and gas sales.69 Data from the World Bank
fuel lobbyists are also often invited by national
comparing the proportion of a countries’ income
delegations and given better access to COP
from natural resources to GDP ranks Azerbaijan
proceedings, typically not in a visible manner.
11th in the world, ahead of Kuwait, Qatar and
Global Witness calculated that the Abu Dhabi Venezuela.70
National Oil Company (ADNOC) and its subsidiaries
Yet even with this vast wealth, inequality in
pursued fossil fuels deals worth US$100 billion while
Azerbaijan is still roughly two times greater than in
its CEO, Sultan Al Jaber, chaired the COP 28 climate
its peer countries in Europe and Central Asia.71 As a
talks, “a five-fold increase on what it pursued in
national oil company, SOCAR effectively operates as
2022 and significantly more in dollar terms than in
an arm of the state. Ilham Aliyev himself was an
the previous four years combined.”68
executive at the company from 1994 to 2003,
The Azerbaijani government delegation at COP 28 in immediately before becoming a member of
Dubai included eight SOCAR representatives. Now parliament, and the company is still ultimately
the Azerbaijani state-owned oil company is playing a controlled by a supervisory committee he
decisive role in the organisation of the COP 29 appoints.72
summit. Indeed, the prominent role of SOCAR in This past year, SOCAR has already positioned itself
Azerbaijan’s state structure and the autocratic at the head of COP 29’s lobbying apparatus. In
nature of the government make it difficult to January 2024, Bloomberg reported that SOCAR
distinguish SOCAR’s interests from those of the executives, including its president Rovshan Najaf,
Azerbaijani host government. President Ilham Aliyev met with US Deputy Special Envoy for Climate Rick
himself is a former SOCAR executive. In this context, Duke at the World Economic Forum in Davos to
there is a serious risk of the diplomatic platform discuss “critical climate change issues”.73 Several
created by the COP Presidency being abused to months later, Najaf followed up with further
meetings with World Economic Forum officials to in
further SOCAR’s business interests.
part promote COP 29.74 He was one of a small

16
 COP CO-OPTED?

carry reports detailing Najaf’s visits to foreign

capitals to sign agreements relating to both SOCAR’s
domestic oil and gas projects and to the company’s
plans for international expansion. These deals have
continued since his appointment to the organising
committee. In July, Najaf and the CEO of the Italian
oil company Eni combined planning for COP 29 with
exploration for new hydrocarbon resources in an
agreement signed in Baku.77
Playing a larger role than Najaf in the organisation
of COP is Mukhtar Babayev, Azerbaijan’s minister of
ecology and natural resources, who will serve as
COP 29 president. Babayev worked for SOCAR
between 1994 and 2018. He worked initially in
marketing and became the company’s vice
Figure 1: Visualisation of SOCAR corporate jet flights 2016 - 2024 president for ecological affairs, as well as a member
of parliament for Azerbaijan’s ruling party.78 A 2010
account from SOCAR’s in-house magazine suggests
number of top Azerbaijani officials and ministers to that the company’s environmental priorities at this
meet with International Energy Agency Executive time focussed on restoring former industrial land.79
Director Fatih Birol on a trip to outline cooperation
in advance of the event.75 Having worked for most of his career in the fossil
fuel sector, Babayev “has little to no past experience
in climate talks”, according to a report in
SOCAR AND THE COP 29 PRESIDENCY Bloomberg80 His trajectory resembles that of COP
28 President Sultan Al Jaber, who worked at ADNOC
In January 2024, President Aliyev announced the as an engineer before establishing and leading
members of the COP29 Organising Committee, a list Masdar, the company’s renewables-focussed
consisting of 28 men and no women.76 After subsidiary.
immediate criticism from international media and A 2008 diplomatic cable from the United States
civil society, the list was revised and at the time of embassy in Baku, published by WikiLeaks,
writing consists of 37 male and 18 female members. documents a revealing conversation with Babayev in
The changes included the removal of Ruslan Aliyev, which he speaks of the importance of “chang[ing]
the director general of SOCAR’s domestic gas SOCAR’s attitude towards the environment, ensuring
distribution division (and of no relation to the that it preserves the environment while fulfilling its
president). But if his removal was intended as a mission to develop Azerbaijan's hydrocarbon
concession to climate activists, it was only a limited resources.” When asked about the level of financial
one. commitment SOCAR is willing to make to this effort,
The most significant SOCAR representative on the Babayev “shift[s] the conversation”, but nevertheless
current organising committee is Rovshan Najaf, the appears “enthusiastic and in possession of a clear
company’s president. Despite SOCAR’s tight vision of what he hopes to accomplish.” The US
integration with Azerbaijan’s broader governing ambassador concludes that “it remains to be seen if
structures – it is ultimately controlled by the he will provide progress or become sidelined like
presidential administration – Najaf has more [the] Minister of Ecology,” a role then held by
responsibility than any other executive for the Huseyngulu Bagirov.81
company’s strategy in both the domestic and the More than 15 years later, SOCAR’s environmental
international arenas. record speaks for itself. A 2022 report by the NGO
Najaf is a former executive director of Azerbaijan Crude Accountability describes a litany of
Investment Company – a fund established to environmental issues caused by the company’s
support foreign direct investment in the country – activities in Azerbaijan, focusing particularly on oil
and plays a prominent role in SOCAR’s international spills and gas flaring, which – given the proximity of
deal-making, a position which makes his presence the country’s oil and gas production to major
on the COP29 Organising Committee especially population centres – also present direct health
problematic. Azerbaijani and foreign media regularly risks.82

17
TRANSPARENCY INTERNATIONAL

Another member of the COP29 Organising any involvement in the businesses or that they
Committee with links to SOCAR is Minister of the represent a conflict of interest.88
Economy Mikayil Jabbarov. He chairs SOCAR’s
supervisory board, a body which exercises “general In the context of COP 29, with the energy transition
management and control over the activities of set to drive a worldwide boom in electrical grid
[SOCAR]” and whose members are appointed construction, signs of corruption in this sector in
directly by the country’s president.83 This Azerbaijan are particularly concerning.
supervisory board also counts Elnur Soltanov,
Azerbaijan’s deputy minister of energy and COP 29
chief executive officer, as one of its members.84
SOCAR’S HISTORY OF BRIBERY AND
The involvement of SOCAR executives and board
members in COP events is nothing new: at COP 28,
UNDISCLOSED PAYMENTS
the Azerbaijani delegation included no fewer than
The conflicts of interest created by SOCAR’s
eight of the company’s senior employees, including
participation in COP 29 are troubling enough on
Najaf and his vice president.85 By placing SOCAR
their own. Compounding the problem, however, is
executives in key positions of the COP 29 planning
the company’s alleged track-record of bribing
process, Azerbaijan risks undermining not only
foreign politicians to promote the interests of the
specific negotiations, but the very structure in which
Aliyev regime. In Europe, Malta’s former prime
those negotiations are set to take place.
minister Joseph Muscat allegedly discussed
receiving kickbacks from SOCAR as an incentive to
strike a gas deal with pricing favourable to
Azerbaijan.89 SOCAR also made illegal political
Power Plays donations to Germany’s Christian Democratic Union
Besides the links with SOCAR, the COP29 in 2012, and contributed to German sports and
Organising Committee’s membership list raises cultural associations during the early stages of the
further questions about the integrity of its construction of the Southern Gas Corridor pipeline
members. network which brings Azerbaijan’s gas to Europe.90 A
2018 report by the Parliamentary Assembly of the
Another businessman on the committee is Council of Europe (PACE) into Azerbaijan’s
Balababa Rzayev, the current chairperson of corruptive activity at the Strasbourg human rights
Azerenerji, Azerbaijan’s largest electrical power body found that the president of SOCAR Ukraine
producer, and longtime former chairman of offered one member a bribe in exchange for
Azerishiq, Baku’s electrical grid operator. He is supporting Azerbaijan’s preferred candidate for
joined on the committee by Vugar Ahmadov, PACE president.91
Azerishiq’s current chairperson. The two The United States has emerged as another target of
companies work closely together. SOCAR’s illicit influence operations. In 2013, the
company used a network of non-profit firms to
In March 2022, Abzas Media reported that
bring nine members of the US Congress and more
Azerenerji had awarded lucrative contracts to
than 30 of their staffers to Azerbaijan.92 The cost of
companies controlled by members of Rzayev’s
the all-expenses-paid trip (which included gifts of
immediate family, including his brother, son and
rugs, silk scarves and crystal tea sets) surpassed
son-in-law. Some of the contracts concerned US$750,000; afterwards, several politicians who
construction of electrical grid infrastructure in attended sponsored legislation and amendments
regions of Azerbaijan previously under Armenian supporting Azerbaijan and its energy sector.93 In the
control.86 The report followed similar allegations end, however, a House Ethics Committee
levelled at Azerishiq in 2020.87 investigations found that members of Congress and
their staffers did not “knowingly“ violate
An investigation by OCCRP in May 2024 revealed
congressional rules, though the head of the non-
how Rzayev’s son, Fuad Rzayev, struck business profit responsible for organising the trip pled guilty
deals in the electricity sector with Georgian to federal charges of concealing the source of the
counterparts, while the elder Rzayev oversaw a funding.94
massive increase in electricity trade between the
two countries. Fuad Rzayev denied his father has

18
 COP CO-OPTED?

Figure 2: European countries where Azerbaijan has been accused of government has embarked on an orchestrated
influencing politicians campaign to win foreign influence by bribing and
And just this past year, U.S. Representative Henry buying off political leaders in exchange for speaking
Cuellar was indicted on charges of accepting over favourably of the Azerbaijani regime.98 Lavish trips
US$360,000 in bribes from SOCAR from 2014 to to Baku and illicit payments were organised for
2021 in exchange for advocating on behalf of politicians by ostensibly dignified organisations such
Azerbaijan in Washington and in his home state of as the European Azerbaijan Society and the
Texas.95 Prosecutors allege that the money flowed Azerbaijan Cultural Center.99
to Cuellar and his wife Imelda through sham Drawing on leaked documents, OCCRP discovered
consulting contracts with shell companies set up by that Baku had created a US$3 billion slush fund to
Cuellar’s wife. Cuellar went on to become one of finance these activities, funnelling the money
Azerbaijan’s biggest boosters in Congress, co- through opaque shell companies.100 The term
chairing the Congressional Azerbaijan Caucus, “caviar diplomacy” itself derives from comments
delivering pro-Azerbaijan speeches, and even made by a senior Azerbaijani policy maker about “a
inserting favourable language into legislation and lot of deputies in the Council of Europe’s
committee reports.96 Former Azerbaijani Parliamentary Assembly (PACE) whose first greeting,
ambassador Elin Suleymanov was so pleased with after 'Hello', is 'Where is the caviar?'".101
Cuellar’s work that he exclaimed, “You are the best
El Jefe!” Cuellar responded, “Yes sir.”97 Azerbaijan’s boldness in approaching sitting
policymakers reached around the world, ensnaring
The Cuellars deny all the charges. In his denial, US and European politicians working in national
Senator Cuellar stated that he and his wife were parliaments, prime ministers’ offices, and especially
innocent and that his legislative actions cited in the pan-European institutions like PACE and the
indictment were “consistent with the actions of European Parliament.102
many of my colleagues and in the interest of the
American people.” Figure 2 shows European countries politicians have
been accused of benefitting from caviar diplomacy.
SOCAR’s allegedly extensive use of bribes to achieve SOCAR has been suspected in several cases of
its international aims exemplifies a broader strategy having provided the finances for the corrupt
adopted by Azerbaijan to engage in “caviar approaches.
diplomacy” abroad. For years, the Azerbaijani

19
TRANSPARENCY INTERNATIONAL

WHAT IS AT STAKE FOR

AZERBAIJAN’S FOSSIL FUEL
INDUSTRY AT COP?

The UNFCCC states that, “hosting a COP presents International Energy Agency (IEA) and others that
a huge opportunity for the host country to the best pathway to meeting the targets in the Paris
promote its approach to climate change Agreement is to stop all new oil and gas exploration.
solutions.”103 Yet, applications to host COP are
In remarks reported by Politico, Elnur Soltanov, the
not vetted by the COP Bureau for commitment
COP chief executive who sits on the supervisory
to the goals of the UNFCCC and the Paris
board of SOCAR, attempted to deflect attention
Agreement. Without improved selection
from fossil fuel producers, saying that rather than
procedures and transparency rules, summits are
focussing on curtailing hydrocarbon production,
at risk of being used to greenwash fossil fuel
countries should focus on emissions.104 These
extraction and other high-emissions industries.
remarks appear to imply an unrealistically large role
At the same time, host governments may seek
in future energy systems for technologies like
to strike new fossil fuel deals and promote fossil
carbon capture, utilisation and storage (CCUS),
fuel interests and solutions supporting their
which have yet to be proven at the scales
current business models.
required.105
Analysis of Azerbaijan’s energy sector ahead of COP
Soltanov’s prominent role organising a global
29 reveals the government’s strategic objectives,
climate summit lends his argument credibility,
which, if pursued under the banner of the COP
Presidency, would fly in the face of consensus on creating a PR opportunity for Azerbaijan (see
how to achieve the goals of the Paris Agreement. Chapter 4). Many of SOCAR’s key international
partners, particularly those based in Europe, may
COP 29 comes at a critical time for Azerbaijan’s fossil
also see Baku hosting the world’s most important
fuel industry. Europe is desperately seeking new
climate summit as an opportunity to legitimise their
sources of natural gas to replace Russian
new joint ventures with SOCAR, potentially
hydrocarbons. This has the potential to bolster a set
of new oil and gas projects in the Caspian Sea that greenwashing new oil and gas projects that are
SOCAR is developing with its international partners. inconsistent with the drive to keep warming below
1.5 degrees Celsius.
COP 29 is also an opportunity for the Azerbaijan
regime to boost the view that oil and gas expansion In this section, we lay out how COP, as both a PR
need not impede climate goals, and that countries opportunity and a potential forum for oil deal-
can pursue both at the same time. This appears to
break with a growing consensus backed by the

20
 COP CO-OPTED?

Figure 3: A methane plum near Baku, Azerbaijan, as shown on

CarbonMapper.org. (Last accessed on 22 October 2024)
autocratic regime with little regard for international
making, runs the risk of emboldening Azerbaijan’s law.
fossil fuel industry and undermining the goals of the As part of this expansion, work took place in
UNFCCC. September 2024 at the Greek–Turkish border to
boost the capacity of the Trans-Adriatic Pipeline.108
Earlier this year, Azerbaijan also signed a
INCREASED EUROPEAN GAS DEMAND cooperation agreement with Turkey to send more
gas from Turkmenistan to Europe.109
Demand for gas from Azerbaijan has soared
because of the EU’s decision to wean itself off The EU is also exploring a deal with Baku and Kyiv to
Russian gas in the wake of the 2022 invasion of let Azerbaijani gas flow through pipelines that
Ukraine. In 2022, Baku made a deal with Brussels to currently carry Russian gas to Europe. The current
increase Azerbaijan's annual gas exports to the EU Russia-Ukraine gas transit deal expires at the end of
to 20 billion cubic metres (bcm) by 2027, a target 2024.
which has since been revised to a still ambitious 16 The demand from Europe for more gas also appears
bcm.106 to have sped up new gas exploration that was
While oil production in Azerbaijan has been in already underway in the Caspian Sea. Whereas
decline since around 2010, gas production has SOCAR and BP had already agreed in 2018 to jointly
continued to grow. Phase Two of the Shah Deniz explore the D230 frontier block over 25 years, and
project – a gas field operated by a joint venture with the first profitable hydrocarbons may not be
BP – supplies the newly minted US$40 billion produced for many years to come.110 In more recent
Southern Gas Corridor pipeline network which takes developments, BP began drilling two new gas
gas from the Caspian Sea through Georgia, Turkey exploration wells on the Shah Deniz and Azeri–
and into Europe.107 Chirag–Guneshli fields in 2023, with the latter
yielding new gas reserves.111
The risk for Europe, and indeed the world, is that a
short-term need for new sources of gas may lead to
an unnecessary expansion of oil and gas
development inconsistent with keeping warming
below 1.5 degrees Celsius, and to dependency on
another gas supply that can be weaponised by an

21
TRANSPARENCY INTERNATIONAL

sharing agreement in place with at least one other

More Gas, More Problems? international partner. This makes Azerbaijan a
As Azerbaijan produces ever-larger volumes of gas valuable source of revenue for several of the world’s
for the European market, the environmental largest oil and gas companies. SOCAR currently has
consequences are still unclear. Methane emissions production sharing agreements with oil and gas
are a major area of concern. A recent study by heavyweights including TotalEnergies, ExxonMobil,
Global Witness found that gas flaring at ADNOC and Lukoil.
Azerbaijan’s onshore and offshore oil and gas
Azerbaijan has no competitive bidding for oil
installations – a significant source of methane, as
contracts, meaning that participating international
well as particulates that are dangerous to human
oil companies trade heavily on their relationships
health – had increased by 11 per cent since 2018,
with the Azeri regime and SOCAR.115 International
when the country last reported methane emissions
firms with stakes in Azerbaijan’s oil and gas sector
data to the UN.112
may see COP 29 as an opportunity to ingratiate
Newly published satellite data also gives cause for themselves with the Azerbaijani regime and SOCAR
concern. The data, derived from measurements to protect their existing assets and to cut new deals.
taken by instruments on board the International It is critical that SOCAR and its international fossil
Space Station and the German EnMAP satellite in fuel interests are not allowed to dominate and derail
April, June and August 2024, shows large methane this year’s COP.
plumes emerging from several locations in the
dense cluster of onshore oil and gas infrastructure
south of Baku (see Figure 3).

Initial analysis of the data suggests that most of

A Time to Celebrate?
the emissions stem from the Garadagh BP is by far the most significant international oil
Underground Gas Storage facility. SOCAR did not company in Azerbaijan and has substantial and
respond to a request for further information on long-running interests in the major oil and gas
the plumes. blocks and key international pipelines. It is no
passive investor either. BP physically operates both
the Azeri-Chirag-Guneshli (ACG) oil and Shah Deniz
gas-condensate fields, two of the most important
DOMESTIC UPSTREAM EXPANSION hydrocarbon projects in the country. It also
operates the Azerbaijani and Georgian sections of
International oil companies are integral to
the Baku-Tbilisi-Ceyhan (BTC) oil pipeline and the
Azerbaijan’s upstream and midstream oil and gas
entirety of the Baku-Supsa (Western Route) oil and
sector, and several of them with stakes in Caspian South Caucasus gas pipelines — critical pathways
Sea exploration and production stand to benefit through which Azeri hydrocarbons reach
from Europe’s rush for new sources of gas. international markets. BP is Azerbaijan’s largest
foreign investor and has a close relationship with
Some of this gas may come from new projects such
the Azerbaijan government going back to the
as BP’s D230, which is still in the exploration phase.
1990s.
The expansion isn’t limited to gas, however: on 20
September 2024, less than two months before the BP has pushed for new frontier exploration in the
beginning of COP 29, BP and SOCAR signed a new Caspian Sea while fawning over Azerbaijan’s ruling
memorandum of understanding for development of family and celebrating the massive amount of oil
and gas extraction it has benefited from over the
the Karabagh oil field.113 Any production of oil and
previous three decades.
gas from new fields jeopardises climate goals. As
International Energy Agency Executive Director Fatih In the run up to COP 29, BP’s Azerbaijan subsidiary
Birol has said, “the pathway to net zero is narrow has been keen to laud its mega-extraction projects
but still achievable. If we want to reach net zero by in the Caspian Sea. At the end of December 2023,
2050 we do not need any more investments in new BP issued a press release celebrating the billionth
barrel of crude oil produced from the West Azeri
oil, gas and coal projects."114
offshore platform.116 West Azeri is part of the
BP is far from the only international oil company in multi-billion-dollar Azeri-Chirag-Gunashli (ACG) oil
Azerbaijan. For the majority of contracts for the field that BP shares with several other companies,
major Azerbaijan deposits, SOCAR has a production most importantly SOCAR.

22
 COP CO-OPTED?

Earlier that month, Bakhtiyar Aslanbayli, BP’s vice geological exploration [for new hydrocarbon
president of communications and external affairs resources] in Kazakhstan.”121
for the Caspian region, published a glowing social
Mirzagaliyev was followed in July 2024 by Askhat
media post celebrating the upcoming 30-year
Khassenov, KMG’s CEO, who visited Baku to discuss
anniversary of the “Contract of the Century” signed
"key cooperation issues” with Najaf and
by BP and Heydar Aliyev – the former president of
colleagues.122
Azerbaijan and father of the current head of state
Ilham Aliyev – to develop the ACG field.117 KMG’s 2023 annual report provides a clear sense of
the company’s priorities, citing the development of a
Aslanbayli’s references to “the Great Leader”
“[r]esource base sufficient to support the Company’s
Heydar Aliyev indicate the deference oil companies
growth” as a key strategic goal.123 This programme
show to Azerbaijan’s ruling family. With so many
of work consists largely of exploratory drilling for
current and future projects at stake in Azerbaijan,
new oil and gas deposits, both onshore and in
BP and other companies appear likely to act as
Kazakhstan’s section of the Caspian Sea.124
powerful allies in the COP Presidency’s campaign
to defend the rights of producing countries to With potential assistance from SOCAR, these hard-
continue fossil fuel extraction. to-recover resources will significantly boost
Kazakhstan’s oil production at a time when experts –
and some international oil companies – have
warned of an imminent peak in global oil
SOCAR’S REGIONAL EXPANSION
consumption.125 In August 2024, having analysed its
reserves, KMG estimated that improvements in
Azerbaijan is not just expanding its domestic oil and
technology would lead to production of an
gas production. Through SOCAR, it is growing its
additional 70 million barrels of oil between 2025 and
portfolio of oil and gas projects abroad. New
2050.
regional partnerships exacerbate the risk that COP
29 will become a platform for fossil fuel deal-making The list of in-person participants at COP 28 shows
rather than a place for real climate diplomacy. no fewer than five representatives from KMG
attending as part of the Kazakh delegation.
Azerbaijan’s maritime neighbours are of particular
Assuming a similar level of attendance at COP 29,
interest to SOCAR since the 2018 treaty partly
many ingredients for high-level deal-making would
settling the states’ contested claims to the Caspian
be in place.
Sea and opening up further opportunities for
extracting its vast underwater hydrocarbon
resources.118 In June 2024, SOCAR Vice President Turkmenistan
Babak Huseynov told reporters: “We are working
Arguably, the state which stands to benefit the most
with Kazakhstan, Turkmenistan, and Iraq to
from the 2018 Caspian Sea treaty – and improving
participate in oil projects. However, the public will
relations with Azerbaijan more generally – is
learn about the results only after the contracts are
Turkmenistan. A border dispute between the two
signed.”119 Open-source information provides
countries has prevented the development of a large
significant additional context about SOCAR’s
oil field known as Dostluk, which lies to the east of
relations with Azerbaijan’s neighbours.
Azerbaijan’s current major offshore projects in the
Caspian Sea, crossing the border with Turkmenistan.
Kazakhstan
In 2021, after many years of diplomatic wrangling,
On 11 March 2024, Kazakhstan’s president Kassym- Azerbaijan and Turkmenistan signed a preliminary
Jomart Tokayev made a state visit to Azerbaijan, agreement to jointly develop the field.126 This was
accompanied by Magzum Mirzagaliyev, chairman of followed in November 2023 by the opening of a
the board of KazMunayGas (KMG), the country’s SOCAR office in Ashgabat, with Azerbaijani Economy
national oil and gas company.120 In addition to Minister Mikayil Jabbarov – a member of the COP29
signing an agreement with SOCAR to increase the
Organising Committee – saying the event “signifies
volume of Kazakh oil pumped to Europe through the
our confidence in the long-term collaboration with
BTC pipeline, Mirzagaliyev gave an interview to the
Turkmenistan, anticipating mutual benefits in the
Trend News Agency in which he revealed that KMG
had invited SOCAR ” to explore opportunities in energy sector for both countries.”

23
TRANSPARENCY INTERNATIONAL

Solving the border dispute and developing the Iraq received a delegation from Azerbaijan –
Dostluk field has the potential to reinvigorate long- including COP29 Organising Committee members
dormant plans for a Trans-Caspian Gas Pipeline Mikayil Jabbarov and Rovshan Najaf – in Baghdad on
from Turkmenistan to Azerbaijan, allowing 18 March 2024.132 According to flight data from ADS-
European markets to access Turkmenistan’s B Exchange, the high-level visit occurred just five
enormous gas reserves. With diplomatic obstacles days after a trip to Baghdad by a corporate jet
apparently removed, the project’s key hurdle now is owned by TotalEnergies and frequently used by CEO
financing, particularly given new restrictions on Patrick Pouyanné.133
using EU funding for fossil fuel projects, as Aliyev
While Iraq’s delegation to COP 28 appears “cleaner”
himself recently pointed out a COP 29-branded
than those of Azerbaijan’s Caspian neighbours, it is
press conference.127128
notable that the group included two representatives
Like Kazakhstan, Turkmenistan fielded a substantial from the country’s board of investment, responsible
team of fossil fuel executives at COP 28, consisting for promoting foreign direct investment in the
of six representatives from its state-owned country.
enterprises Turkmengas and Turkmenoil. The
delegation included both the head of Turkmengas
and the CEO of its subsidiary TAPI Pipeline Company AZERBAIJAN’S PROGRESS IN RENEWABLES
Limited, which is building a pipeline to Afghanistan,
Pakistan and India. Azerbaijan is aiming to increase the share of
renewable energy sources – principally utility-scale
Given the increasing alignment of economic
solar and offshore wind – in its installed electricity
interests between the various Caspian states and
generating capacity to 30 per cent by 2050.134
the EU, and the potential for a substantial pay-day
for the current licence-holder, development of the Calculations of capacity use energy sources’
Dostluk field and the proposed Trans-Caspian Gas theoretical maximum output. As photovoltaic cells
Pipeline should both be seen as high-risk areas for and wind turbines are intermittent sources with
fossil fuel deal-making at and around COP 29. significantly lower capacity factors than gas
turbines, 30 per cent of installed capacity may
Iraq produce a significantly lower percentage of total
electricity supply.
SOCAR’s final area of potential upstream expansion
Even with this caveat, Azerbaijan has made
is in Iraq, where huge oil reserves – the fifth largest
significant progress in in renewable energy projects
in the world – remain undeveloped.
in recent years. However, analysis of developments
In 2022, following several high-level visits to Baku, in solar and wind power shows how tightly
the state-run Iraqi Drilling Company (IDC) signed a integrated their deployment is with Azerbaijan’s
partnership with SOCAR for drilling and oil field broader system of fossil fuel extraction, with plans
services.129 The three-year deal is set to expire in to use renewables to provide power to energy-
2025, and its renewal may therefore be a key intensive oil and gas production processes.135
priority for Iraqi delegates at COP 29. Perhaps more
significantly, SOCAR may seek an ownership stake in Solar power
one or more of Iraq’s oil and gas fields, either
individually or as part of a consortium. Azerbaijan’s climate and landscape make it well
suited for solar energy. According to figures from
In 2023, the French oil major TotalEnergies – a key
the Ministry of Energy, the country’s technical solar
partner of SOCAR’s in the Caspian Sea – closed a
potential is around 23 gigawatts (GW).136 By
US$27 billion energy deal with the Iraqi government
contrast, a recent bottom-up analysis of global solar
and partner QatarEnergy.130 The news followed a
deployment using satellite imagery puts the
significant downsizing of other oil majors’
country’s total installed capacity at less than 0.3
operations in the country. While press for the deal –
GW.137
named the Gas Growth Integrated Project (GGIP) –
has focussed on plans to improve the country’s Azerbaijan has only one operational utility-scale
electricity supply by capturing and using flared gas, solar facility, the 230-megawatt (MW) Garadagh
the programme of work also includes plans to plant. Garadagh (formerly known as Area 60) was
“increase regional oil production” by injecting built by Masdar, a renewables-focussed subsidiary
desalinated seawater into wells.131 of the UAE’s state oil company ADNOC, whose

24
 COP CO-OPTED?

website boasts that the facility will power 110,000 favour large European oil companies like BP and
homes.138 TotalEnergies.147

The Shafag project is another large solar farm under Azerbaijan already plans to use solar energy to
development by SOCAR and BP on territory taken by decarbonise elements its midstream oil and gas
Azerbaijan from Armenian forces in 2020. Shafag industry. The management of a major roll-out of
will supply electricity to the local grid, reducing the offshore wind projects in the Caspian Sea by
need for gas-fired generation. At the same time, BP international oil companies risks similar effects,
will convert parts of its Sangachal oil and gas powering an increase in oil and gas production and
terminal near Baku to run on electrical power, further entrenching the region’s position as a zone
resulting in a net reduction in the amount of gas of extraction and environmental damage.
used for electricity generation in Azerbaijan.139
The key for Azerbaijan – as with any oil-producing
As the NGO Crude Accountability has pointed out, country, including those in the Global North – is to
this move to save gas appears to have been made phase out upstream oil production while
with an eye toward Azerbaijan’s export implementing renewables in a way that powers both
commitments.140 Speaking in 2022 in the town of the needs of everyday people and the industries of
Shusha, which Azerbaijan gained control of less than the future.
two years earlier, BP’s regional president for
Azerbaijan stated explicitly that the electrification of
Sangachal would allow the company to “export the
displaced gas through SGC [the Southern Gas
Corridor].”141

In addition to Garadagh and Shafag, there are three

major solar projects totalling 1.16 GW in early stages
of development by Masdar and Nobel Energy.142

Wind power
According to data from Global Energy Monitor,
Azerbaijan currently has just one operational wind
farm, the 50 MW onshore Yeni Yashna project
located north of Baku.143 Three other onshore
projects totalling around 500 MW of installed
capacity are currently under construction by SOCAR,
Masdar and the Saudi Arabian company ACWA
Power.144

Analysts see the vast majority of Azerbaijan’s

potential wind energy – up to 157 GW of technical
capacity by some estimates – offshore in the
Caspian Sea.145 To tackle the technically and
financially challenges of exploiting this resource, the
Azeri government has published a long-term plan
under the World Bank’s Energy Sector Management
and Assistance Program.146 In addition to setting
long-term targets, Azerbaijan’s offshore wind plan
appears to set the stage for continued dominance of
the country’s energy system by a small handful of
fossil fuel companies. The plan states explicitly that
bidders for the development of offshore wind
projects “will require experience in both [offshore
wind] project development (from other markets)
and in Caspian Sea project execution (through
hydrocarbon activities).” These criteria strongly

25
 COP CO-OPTED?

SMOKE & MIRRORS? CIVIL

SOCIETY & MEDIA ENGAGEMENT

The UNFCCC formalises the role of civil society is yet to officially release for COP 29, should contain
groups as “observers,” enabling them to guarantees that all human rights will be protected
participate and attend COPs once their and respected by the COP hosts.148 Human Rights
application has been granted by the UNFCCC Watch has obtained and published a copy of the
Secretariat. The UNFCCC Secretariat is also COP 29 HCA, though it is missing annexes that
responsible for approving applications for media provide important detail on the arrangements
accreditation. Civil society groups – particularly between the UNFCCC and Azerbaijan.149 The HCAs
those representing traditionally marginalised for both COP 28 and COP 29 prohibit participants
groups such as Indigenous people or low-income from interfering in the “internal affairs” of the host
populations – often give voice to those most country – a troubling clause in contexts where
directly affected by the current impacts of human rights and free speech are under attack.
climate change and are a critical constituency in
As discussed in Chapter 2, no true independent civil
any attempt to realise a just transition, even if
society exists in a non-democratic regime such as
they often don’t have a formal seat at the
Azerbaijan. The fact that the Azerbaijan regime
negotiation table.
routinely silences activists and journalists through
Given the risks of hosts using COPs to whitewash imprisonment and detention makes the full
their human rights records and co-opt the publication of the COP 29 HCA document and clarity
summits for their own interests, it is vital that on these matters all the more urgent. In June,
the host country guarantees the active Human Rights Watch identified 25 cases of
participation as observers of truly independent, Azerbaijani journalists and activists being silenced in
non-governmental civil society before, during, the preceding 12 months.
and after COP. Civil society activists and media
Based on the information available, however, the
organisations provide an essential check on the
COP 29 Presidency appears to be setting up two
powers of governments and companies that
parallel processes to exert influence over these
traditionally have influence at COP. The ability
critical watchdogs.
of these groups to express themselves freely,
contribute to solutions and highlight issues is
essential to realising the desired ambitions of
THE COP29 NGO COALITION
climate negotiations, ensuring key voices are
heard, and preserving the integrity of COP. This
On 10 September, several members of the COP 29
also includes guaranteeing no obstacles to
Presidency Team, including President-designate
participation, including indirect ones like
Mukhtar Babayev, joined a video call with members
unaffordable accommodations.
of the COP29 NGO Coalition, a newly formed
As Amnesty International has already argued, the collection of civil society organisations from
Host Country Agreement (HCA), which the UNFCCC Azerbaijan and abroad.150

26
 COP CO-OPTED?

The COP29 NGO Coalition was convened by the Azerbaijan – which ranks in position 164 out of 180
National NGO Forum, whose main partner is the countries in the World Press Freedom Index by
government’s Agency for State Support to Non- Reporters without Borders156 – the organisation
Governmental Organisations. That agency was consistently takes a strongly pro-Aliyev position in
created, and its board members are appointed, by public outputs. These include a report on the
presidential decree.151 country’s February 2024 presidential elections, in
which the group accuses independent OSCE
The executive director of the Agency for State
monitors of bias and whitewashes the activities of
Support to Non-Governmental Organisations is a
the ruling party.157 IEPF has planned joint events
member of the COP29 Organising Committee. In
with IRDG on Nagorno-Karabakh and signed a
June, the National NGO Forum and Agency for State
formal cooperation agreement with GIWEH.158 Its
Support to Non-Governmental Organisations
head, Umud Mirzayev, also sits on the board of the
organised a meeting between NGO representatives
Azerbaijan Press Council, an organisation which
and SOCAR to discuss SOCAR’s green energy
local journalists have called “meaningless” due to its
agenda.152
adoption of pro-regime positions.159
The COP29 NGO Coalition sits outside the formal
IRDG, GWIEH and IEPF did not respond to requests
UNFCCC process for participation by civil society and
to comment on their relationship with each other
has been promoted by Azerbaijani media in the run-
and their apparent history of taking positions that
up to the event. While the process for joining the
support Azerbaijan’s domestic and foreign policy
coalition is unclear, and the organisers have not
goals.
published a list of member organisations, a
recording of a meeting posted on YouTube, and The COP29 NGO Coalition appears to include
several screenshots of virtual meetings published by participants with direct links to the Azerbaijani
the National NGO Forum allow us to identify some government. These include Azer Allahveranov,
participants. whose biography on X describes him as chairperson
of the Eurasian Migration Initiatives Platform.160
Several participating NGOs appear to have close ties
According to his LinkedIn profile, Allahverov served
to the Azerbaijani state.
for eight years as chairperson of the State Migration
Among those present on calls are representatives Service of the Republic of Azerbaijan’s Public
from two closely linked Geneva-based groups: the Council, a body which engages with the government
Institute for Rights and Development – Geneva on migration issues.161 Allahveranov sits on the
(IRDG) and the Global Institute for Water, Supervisory Board for the Agency for State Support
Environment and Health (GIWEH).153 IRDG and to NGOs, a position to which he was appointed by
GIWEH have been vocally supportive of Azerbaijan President Ilham Aliyev, and was elected to
in recent years, particularly on two issues that relate parliament in Azerbaijan’s recent parliamentary
to the conflict with Armenia: the clearing of elections. His social media profiles are full of
landmines in territories formerly controlled by appearances on state television and statements
Armenia, and pollution of the Okhchu river with which are highly supportive of Azerbaijan’s COP 29
waste from Armenian industrial operations. presidency.
In December 2022, IRDG organised a ‘protest Organisations which campaign on the central
exhibition’ about the landmine issue outside the challenge of climate change – reducing global
United Nations office in Geneva displaying signs dependence on fossil fuels – appear to be grossly
criticising “Armenian War Crimes.” The protest was underrepresented, if not completely absent, from
promoted on the website of the State Committee on the Coalition, as well as from other initiatives
Work with Diaspora of the Republic of Azerbaijan.154 organised by the NGO Coalition. The UNFCCC’s
The organisations’ joint events have been reported handbook for COP hosts states that they should:
extensively in the Azerbaijani media, as have their “pursue a broad stakeholder engagement strategy
written submissions to the UN’s Human Rights based on transparency, openness and
Council.155 inclusiveness.”
Another organisation attending meetings of the The National NGO Forum and COP 29 organisers did
COP29 NGO Coalition – and which appears to be not respond to requests for comment on the
part of the same loose network as IRDG and GIWEH membership, purpose or approval process of the
– is the International Eurasia Press Fund (IEPF). COP29 NGO Coalition.
Purporting to support a thriving media sector in

27
TRANSPARENCY INTERNATIONAL

In many ways, the COP29 NGO Coalition resembles

the “BTC Support and Monitoring International
STRATEGIC PR BLITZ
Public Coalition”, established by the National NGO
COP Host Country Agreements regulate media
Forum in 2002 to promote the development of the
services and operations by the UNFCCC and the
Baku–Tbilisi–Ceyhan (BTC) oil pipeline by countering
host government. The Agreement with Azerbaijan
legitimate criticisms from local and international
has not been officially released, and the version
environmental and human rights NGOs.
obtained and published by Human Rights Watch
According to a 2014 account from Azeri media, does not include the relevant annex detailing
sympathetic to the government: responsibilities for media and communications.
However, in the previous agreement with the UAE,
“In 2002, the National NGO Forum established the
the UNFCCC communications team is responsible
"BTC Support and Monitoring International Public
for “strategic communications, including
Coalition" [BTC-yə dəstək və monitorinq beynəlxalq
communications policy, coordination on media
ictimai koalisiyası] in order to neutralise
issues with the COP President, briefings…
[neytrallaşdırmaq] the activities of 64 foreign NGOs
preparation of press releases, press reviews” and
covering more than 30 countries of the world, which
other communications functions related to people
purposefully started the "Anti BTC" coalition.”162
and processes within the UN system. The host
As James Marriott and Mika Minio-Paluello note in government, meanwhile, is expected to appoint a
The Oil Road, a 2012 book on the pipeline and the communications liaison officer that helps promote
campaign against it, the pro-pipeline coalition was the conference in local and international media
led by Sabit Baghirov, a high-level SOCAR executive interest and issue accreditations.166
with significant responsibility for delivering the
In practice, however, the line between a neutral
pipeline itself.163
convenor promoting the agenda of the conference,
The National NGO Forum did not respond to a and a nation state promoting its own image on the
request for comment. world stage can easily become blurred. When the
host nation is an authoritarian petrostate with an
More recently, Azerbaijan has been accused of
interest in pursuing fossil fuels expansion, these
leveraging civil society and environmental issues
conflicting agendas can become particularly
over the 2022–23 blockade of the Lachin Corridor,
problematic.
when a protest by dozens of state-affiliated NGO
workers – alongside military personnel, civil servants The loud criticism of the UAE as COP 28 host seems
and youth organisations – blocked the only exit not to have been lost on Azerbaijan. To manage the
route from Armenian-controlled territories in impending scrutiny, the COP 29 organising team
Nagorno-Karabakh.164 sought professional help. Beginning on 1 February,
2024, the COP 29 Presidency began employing the
It is unclear to what extent membership of the
services of Teneo, one of the “Big Four” firms
COP29 NGO Coalition allows organisations to
working globally in strategic communications.167
influence the priorities of the presidency.
Teneo has represented a small number of foreign
Azerbaijan’s draft initiatives had already been
clients in the United States over the last five years,
circulated before the video call attended by the
including many powerful organisations and
presidency team. On the call, Shahriyar Hajiyev, an
companies in the UAE, Saudi Arabia and other
Azerbaijani diplomat responsible for outreach to
authoritarian petrostates. Azerbaijan is next in line
observer organisations, encouraged participants to
to tap this expertise to improve its international
follow the website of the COP 29 Presidency and
reputation and advance its agenda in the run-up to
send written proposals and amendments for
COP 29.
consideration. He also appeared to encourage
coalition members to find ways around the UNFCCC The contract Teneo signed with COP29 Azerbaijan
accreditation process, telling the call: “We would like Operations Company is worth US$4.7 million with a
to encourage the NGOs that don’t have observer monthly retainer of US$475,000 and one-time
status to learn the procedures from the UNFCCC payments of US$1.425 million and US$950,000 for
Secretariat. There can be other possibilities for
its work in May and June.168 Since the COP 29 team
them. For example, through cooperation, they can
is considered a foreign entity in the United States,
receive quotas from international partners and
Teneo is required to regularly file as a foreign agent
receive badges and participate at COP 29.”165
under US law for any lobbying or promotional

28
 COP CO-OPTED?

activities it conducts in that country. These filings

provide incredible insight into the nature of the
Azerbaijani PR blitz surrounding COP 29, including
the nature of the contract, outreach activities,
expenses, and personnel. For example, its latest
FARA filing shows that in the six months from
February to July 2024, Teneo racked up more than
US$550,000 in expenses, including airfare, hotels,
meals, and other consulting fees.169

This contract engages Teneo in the direct planning

and promotion of COP 29 in Baku. According to its
FARA filing from 30 August 2024, Teneo has helped
“to establish the COP 29's communications function,
including narrative development, initial content
development, communications and engagement Figure 4: Visualisation of Teneo's outreach to 15 media outlets 1
February – 31 July, 2024.
campaign planning, issues management,
organisational development, establishing media
from July was with Azerbaijan’s ambassador to the
relations capability, and media training.”170 Other
Netherlands, Rahman Mustafayev, who later co-
activities include polling and mapping stakeholders.
convened a conference on COP 29 at The Hague in
Some of that content may have included drafting September.173 Messages to journalists also appear
the speeches COP 29 President Mukhtar Babayev to include numerous invitations to join media trips
gave to the Petersberg Climate Dialogue in Berlin on to Azerbaijan, exclusive briefings with COP 29
25 April 2024 and that COP 29 Lead Negotiator organisers and the dissemination of talking points.
Yalchin Rafiyev delivered to the Bonn Climate
The articles produced tend to focus on the COP 29
Change Conference on 10 June, 2024. The texts of Presidency’s priority of convening a summit focused
both addresses appear as “Informational Materials” on climate finance.174 Azerbaijan’s geographic
submitted as separate FARA filings.171 Though it is
location and status as an oil-producing developing
possible that Teneo was only distributing the
country is framed as an opportunity to bring the
speeches to journalists ahead of the meetings, their
global North and South together to negotiate new
inclusion in the FARA filings may also indicate Teneo
monetary commitments. However, several
helped develop their content.
interviews also give Azerbaijan’s officials a platform
Teneo did not respond to a request for comment. to defend their own energy policies.175 In these
articles, continued fossil fuel expansion driven by
Perhaps the most striking details in Teneo’s FARA
European demand for gas is presented as a
filings on behalf of the COP29 Azerbaijan Operations
necessary part of the green energy transition.
Company involve its extensive outreach to
journalists from around the world to promote Largely missing from the articles generated by
Baku’s agenda for the COP 29 event. In its two filings Teneo’s campaign is mention of Azerbaijan’s human
so far in 2024, Teneo documents 505 unique rights record, autocracy, corruption and kleptocracy.
approaches to journalists. Azerbaijani officials’ stated commitment to
inclusivity and transparency goes unchallenged by
Figure 4 visualises this outreach for the top 15
examples of the government’s normal practice.
media outlets targeted, with each coloured line
indicating an email, text message, or other The Quincy Institute for Responsible Statecraft has
communication sent from Teneo between 1 raised concerns about the Teneo campaign for the
February 1 and 31 July (the last date for which we COP29 Azerbaijan Operations Company, suggesting
have data). that it may be engaging in “peacewashing” by
promoting a “COP Truce” initiative, while the conflict
The detailed nature of the outreach descriptions
with neighbouring Armenia remains formally
suggests that Teneo assisted in setting up at least 10
unresolved.176 As noted in that article, COP 29
interviews for COP 29 President Mukhtar Babayev,
President Babeyev used an appearance on
Lead Negotiator Yalchin Rafiyev and COP 29 CEO
Azerbaijani TV to laud Teneo’s success in changing
Elnur Soltanov with major international news outlets
international perceptions of Azerbaijan, saying “Now
from March to the end of July.172 One interview

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TRANSPARENCY INTERNATIONAL

they all understand and see the strength of our support for Azerbaijan’s actions in Nagorno-
country.”177 Karabakh (including contacting US congressional
offices more than 1,000 times in the first half of
Responsible Statecraft also highlighted an apparent
2023).184 In the EU, this PR blitz may have included
breach of Teneo’s obligation to register as a foreign
sponsoring favourable coverage on the website EU
agent before beginning work for the foreign
Reporter, which regularly featured articles “effusive
government. The PR campaign began in February,
in their praise for Baku.”185
but Teneo only registered in June. Teneo did not
respond to a request for comment from the authors What is new is the size of the single contract with
of this report. Teneo and the powerful communications and
The latest FARA filing also listed 16 persons from six human resources being dedicated to shape the
different countries actively working on behalf of the image of Azerbaijan through its hosting of COP 29.
COP29 Azerbaijan Operations Company, including The total budget Azerbaijan has allocated to just this
Geoff Morrell, Teneo’s president of global strategy one public relations campaign rivals what it
and communications. Prior to joining Teneo in 2023, contributed to the UNFCCC just to host the
Morrell had worked at British Petroleum (BP) from conference. According to the copy of the COP 29
2011 to 2022, ending his time there as executive vice Host Country Agreement obtained by Human Rights
president of communications and advocacy.178 At Watch, Azerbaijan paid UNFCCC around US$5.8
BP, Morrell helped rebuild BP’s reputation following million to "bear the actual additional costs directly
the Deepwater Horizon oil spill, where he led a risky
or indirectly involved in holding the Conference in
strategy to be the “villain playing the victim” in order
Baku, Azerbaijan rather than in Bonn, Germany."186
to reduce what BP viewed as fraudulent liability
claims.179 At Teneo, Morrell led a controversial
US$2.7 million contract with the Saudi Public
Investment Fund to manage the public relations
around the LIV golf tour’s partnership with the
PGA.180 Teneo CEO Paul Keary was later called to
testify at a US Senate permanent subcommittee
about this work, explaining why the firm – along
with three other consultancies – failed to hand over
documentation to assist the committee’s
investigation.181

Another high-powered Teneo employee involved in

work on COP 29 is Senior Managing Director Alex
Hickman. According to his LinkedIn profile, Hickman
– originally a journalist – joined Teneo in November
2022 after working for more than two years as a
special adviser on business issues to former UK
prime minister Boris Johnson.182 The move was
scrutinised by the UK’s Advisory Committee on
Business Appointments and led to criticism in the
media over the apparent “revolving door” between
government and the private sector.183 Hickman’s
work at Downing Street, which followed a stint with
the successful Vote Leave campaign for Britain to
leave the European Union, coincided with the UK’s
hosting of COP 26 in Glasgow.

Employing Western public relations to beef up the

regime’s image has long been a favoured tactic of
President Aliyev. Data from OpenSecrets shows that
the Azerbaijani government spent nearly US$8.5
million between 2016 and 2023 on lobbying its
interests in the United States alone. That cash
helped finance an elaborate campaign to bolster

30
 COP CO-OPTED?

CONCLUSION

The annual COP event is being co-opted by fossil damaging to human rights, the
fuel companies as well as other commercial, political environment, democracy and the climate.
and personal interests potentially in conflict with the
This report has shown how these systematic risks
central aim of staving off climate change. At its core,
may be exploited by the Azerbaijani government
COP must act as a forum to bring world leaders
and fossil fuel interests that seek to use COP 29 to
together to make credible commitments to reduce
pursue their own interests.
greenhouse emissions and facilitate action. But the
lack of rules and transparency requirements for the The COP host “Troika” – UAE, Azerbaijan and Brazil –
COP community, and the UNFCCC Secretariat in will not be the last oil-producing economies to host
particular, is a systematic vulnerability that self- a UNFCCC climate summit. Depending on the host
interested parties can exploit for their own ends. As selected, other industries – including oil and gas,
the findings in this report show, these risks are mining and other energy-intensive sectors – may
especially prominent when the COP is hosted by
also seek to capture the COP process for their own
governments, such as Azerbaijan for COP 29 in 2024
gain. But the UNFCCC can, and must, take measures
and the United Arab Emirates for COP 28 in 2023,
to protect the integrity of the COP when such
with authoritarian rule187 or high levels of
conflicts of interest arise in the future. The
corruption, and a dependency on the extraction and
export of fossil fuels. development and deployment of a playbook by
which host governments could exploit the
Specifically, under the current rules for governance proceedings to advance their own agenda would
and organisation, COPs run the risk of:
constitute a fundamental threat to the integrity of
• outsized influence for national and UN climate conferences. Fortunately, the anti-
international fossil fuels corporations corruption and climate communities have
during the organisation of the event, the developed a series of measures that can help
negotiations taking place during it, and the counter the undue influence of polluting industries,
development of the diplomatic platform corrupt officials and their enablers. The
and action agenda produced by the summit
recommendations made in this report apply this
• personal enrichment of politically best practice to the COP context.
connected elites through the co-opting of
However, attention to these conflicts of interest, and
the summit’s organisation and negotiations
measures to address them, should not be applied
• the cynical manipulation of media and civil only when the risks are at their greatest. Every host
society interests to further the agenda of should be obliged to implement fundamental
the host country, deflect legitimate transparency practices to ensure an open and level
criticism, and greenwash practices playing field at COP and that a multilateral, science-
backed consensus comes first.

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TRANSPARENCY INTERNATIONAL

In September 2024, while this report was being commitment to the goals of the Convention
prepared, the United Nations signed a Pact for the and the Paris Agreement, the purposes and
Future. This document redoubled signatory states’ principles of the Charter of the United
commitment to multilateral, science-backed Nations, and international human rights
responses to collective challenges. In the spirit of law before, during and after UNFCCC
this pact, the UN must protect the conditions in sessions and mandated events;
which a common agenda can thrive at the COP.
• These requirements should be reflected in
When the pact was adopted, the president of Brazil, the handbook on hosting a COP.
the country that will host COP 30, Luiz Inácio Lula da
Silva, announced a “global ethical stocktaking, Transparency around COP preparations and
bringing together different civil society sectors to hosting arrangements
think about climate action from the perspective of The host country must abide by the UNFCCC’
justice, equity and solidarity.”188 process for due diligence and criteria190 for selection
Such a stocktake and the G20 proposal by Brazil, to of corporate partners. It should only allow
put “anti-corruption be at the centre of policies to sponsorships from entities that demonstrate
combat climate change”189 provide a recognition of commitment to the United Nations Global Compact
the need for more integrity for successful climate and the United Nations Guiding Principles on
action and constitutes a welcome opportunity Business and Human Rights.
to address the findings of this report and begin the • HCAs must include a commitment to
implementation of the recommendations listed uphold international human rights law
below. before, during and after UNFCCC sessions
and mandated events. This should include
immunity of observer organisations’
RECOMMENDATIONS representatives and other persons from
legal process in respect of words spoken or
Integrity over the choice of the host country written and any act performed by them,
Current practice does not prevent unsuitable within and outside conference premises.
governments from becoming the hosts of the most
• The host country should engage in HCA
important global gathering on climate change and
discussions in a transparent way and make
using the COP Presidency to privilege national or
the draft HCA available for feedback.
specific industry interests over the common good.
The COP should follow a more robust process to • In line with the June 2023 guidance from
select host countries: the Subsidiary Body for Implementation
(SBI),191 HCAs should be published
• In addition to the current logistical,
promptly on the UNFCCC website as soon
technical, and financial considerations, the
as they are signed.
Secretariat should assess and report to the
Bureau on whether the prospective host • HCAs should make the UNFCCC
country provides a conducive environment Secretariat’s approval of partners
for all participants, particularly compulsory. Specifically, HCAs should
representatives from observer follow the UNFCCC “process for due
organisations, to exercise their human diligence and criteria for selection of a
rights without fear of intimidation and partner,” and include similar provisions to
repercussions, as well as guarantee prevent sponsorship by entities “whose
reasonable costs for participation, thus products, services or operations may
allowing that concerned groups with negatively affect the objectives, activities or
limited resources have equal access to reputation of the secretariat, including but
negotiations; not limited to entities whose core products
or core related services include fossil
• The COP should only consider expressions
fuels.”192
of interest that have been vetted by the
Bureau of the COP, after review and • Host deals involving corporations and
confirmation by the Secretariat that the organisations granted Green Zone partner
proposal of the government demonstrates or exhibitor status must be published on

32
 COP CO-OPTED

the UNFCCC website so that financial and their reasons for participation, should be made
relationships are open to public scrutiny. publicly available.

• The UNFCCC must establish clear guidelines • The UNFCCC Secretariat should improve
governing the use of the COP brand in host and enforce transparency requirements for
country initiatives and diplomacy to prevent the registration of COP participants, so that
misuse that could promote endorsement of their most relevant affiliation is
solutions serving fossil fuel interests or compulsorily declared and publicly released
policies that contradict the goals of the well ahead of the COP. This information
UNFCCC and the Paris Agreement. should also be made visible during the COP.
Accountability of the COP Presidency • All COP organisers and delegation
attendees should be required to declare
The Presidency must be impartial, even if the
any significant financial interests in,
appointing government has interests that conflict
sponsorship by, or control over entities
with science-aligned guidance for delivering the 1.5-
whose core products or core-related
2 degrees Celsius goal of the Paris Agreement. To
products, services or operations may
preserve this impartiality, the Bureau of the
negatively affect the objectives, activities or
Conference of the Parties (COP) must substantially
reputation of the UNFCCC, including but not
review the Code of Ethics for Elected and Appointed
limited to fossil fuels.
Officers. Particular attention should be given to
Article 14, to include the following: • The COP should establish a conflict of
• the obligation to disclose any situations or interest policy that clearly defines a conflict
relationships, financial or otherwise, that of interest, sets out disclosure
might be perceived as affecting the requirements, and details how conflicts will
objectivity and impartiality of the be managed. It should ensure that all COP
presidency in an interest disclosure form participants, including delegates, observers,
that must be made publicly available on the and exhibitors, formally agree to abide by
website of the UNFCCC Secretariat; this policy as a condition of their
participation.
• the incompatibility of the position of
president with any role (remunerated or • All delegations should adhere to the highest
not) and any holding financial or vested standards of transparency regarding whom
interests in an entity whose core products they invite in their delegations and
or core related products, services or meetings with lobbyists in preparation for
operations may negatively affect the and during COP.
objectives, activities or reputation of the
Business responsible engagement
UNFCCC, including but not limited to fossil
fuels; All private sector entities participating in the COP as
part of government delegations and observer
• the public disclosure of all formal and organisations must adhere to minimum standards
informal meetings held in connection to the for responsible political engagement. In line with the
role of the presidency, with an indication of Global Standard on Responsible Climate lobbying193,
the topics addressed and attendees; organisations should publicly disclose:
• the establishment of a clearly outlined • the policy issues or regulatory acts related
process to deal with arising conflicts of to their lobbying activities, with an
interest and non-adherence to ethical rules; indication of their positions regarding the
Paris Agreement goal of restricting global
• effective rules to enforce the replacement
warming to 1.5 degrees Celsius above pre-
of the president when he or she violates
industrial levels;
ethical duties.
• their expenditures on lobbying,
Transparency and accountability around COP
sponsorships, and other political
participation
engagement activities;
The COP is an international UN space. All
information about whom the participants represent,

33
TRANSPARENCY INTERNATIONAL

• the links to any public policy statements

and research sent to public decision-
makers, as well as to all transparency
registers in which the entity is registered;

• the list of individuals in their senior

management, board or in advisory
positions who have previously or currently
hold, or are otherwise seconded to, a
position in government on climate matters
or a government delegation to COP.

34
 COP CO-OPTED?

ENDNOTES

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COP 29. Press releases:

September 13, 2024. First Partners for COP29 announced.”

Available at: https://cop29.az/en/news/first-partners-for-cop29-announced

September 17, 2024: “Rhenus Group Announced as Partner for COP29”

https://cop29.az/en/media-hub/news/rhenus-group-announced-as-partner-for-cop29

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This publication was produced with financial
support from the Waverley Street Foundation under
Transparency International’s Climate Governance
Integrity Programme. Its contents are the sole
responsibility of Transparency International and
ACDC and do not necessarily reflect the views of the
Waverley Street Foundation

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