Vibra Energia SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Vibra Energia SA has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company explicitly names several specific climate policies it has engaged with, such as "Bill 1873/21, running in the Chamber of Deputies, creates the National Program for Advanced Renewable Fuels," "Bill 528/21, pending in the Chamber of Deputies, creates the Mandatory National Program for Emissions Compensation," "The Fuel of the Future Program, under development by the Federal Government," and "Public consultation and Public Hearing ANP No. 11/2022 - ANP Resolution No. 50/13 review." These disclosures provide detailed information about the policies and their objectives, demonstrating transparency in naming the specific climate-related legislation and initiatives engaged with. Vibra Energia also provides detailed information about its lobbying mechanisms and targets, including "taking technical data to meetings with policymakers," "encouraging the participation of trade associations," "directly participating in debates and public consultations," and "responding to consultations with policymakers." It identifies specific targets, such as "parliamentarians who report on bills on the matter, such as Bill No. 412/22," "the parliamentary rapporteur of Bill 1873/21," and "the formulator of the Fuel of the Future Program in the Federal Government." Furthermore, the company has been explicit about the outcomes it seeks through its lobbying efforts, such as promoting the adoption of sustainable energy solutions, increasing the blend of ethanol in gasoline and biodiesel in diesel, advancing the commercialization of biogas and biometano, and supporting the regulation of the carbon market. Vibra Energia also aims to "encourage research on advanced biofuels-related and to promote its production and consumption" through Bill 1873/21 and supports the creation of the "Brazilian Emission Reduction Market (MBRE)." These disclosures clearly outline the desired policy changes and objectives, demonstrating a high level of transparency in its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Vibra discloses that it "systematically monitors and analyzes the opportunities for public policies that may impact its activity and proposes them," demonstrating a structured approach to ensuring consistency with its climate change strategy. The process involves the institutional relationship area, which is "responsible for leading public policy opportunities," and requires consultation with various departments, including ESG, which "coordinates the company's climate change strategy," thereby helping align "internal processes that directly or indirectly influence public policies" with Vibra's climate goals. Although other evidence does not mention specific governance details or references to climate lobbying processes, the company's explanation of how relevant areas formally review and provide input on proposed public policy opportunities indicates strong governance of climate lobbying. This approach shows thoughtful oversight and coordination designed to maintain alignment with Vibra's climate objectives.	3