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Alfa emphasizes "SUSTAINABILITY GOVERNANCE" and lists "Policies and guidelines" and "Business ethics and transparency" as core elements of its ESG framework, assigning oversight roles down to the "Business Units’ Sustainability Directors". However, the report makes no mention of "lobbying", does not identify who "oversees or reviews" lobbying activities, nor describe any process for aligning direct or indirect advocacy with its policies. We found no evidence of any mechanism—such as a "lobbying review", board sign-off on lobbying strategy, or trade-association screening—to ensure lobbying alignment. This indicates that Alfa does not disclose a governance framework specific to its lobbying activities.
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