Altri SGPS SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Altri SGPS provides a generally clear picture of its climate-policy engagement. It names the individual measures it has worked on, including the “Revision of the renewable energy directive (RED II),” the “Revision of the European Emissions Trading System (ETS) regulation,” and the “Portuguese climate and energy strategy,” demonstrating openness about the exact legislative files it seeks to influence. It is also explicit about the policy objectives it pursues, stating support for the European Commission’s goal that “all packaging must be recyclable or reusable by 2030,” calling for “effective and proportionate measures to halt deforestation,” and advocating that the ETS continue to offer “free allocation and harmonized indirect carbon cost compensation” so that the sector retains a “favourable investment environment.” The company explains that “specific representatives focusing on the policy issues on the EU level, Portugal, and Spain” meet directly with policymakers and other stakeholders, but it gives only limited detail on the range of channels used and does not identify individual institutions or consultation formats. Overall, the disclosure is strong on the policies covered and the positions taken, while only partially elaborating the mechanisms and precise targets of its lobbying activity.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Altri SGPS SA has established a sustainability governance structure that integrates climate matters at the corporate level, creating a Sustainability Working Group (SWG) whose mission is to support a “Director who leads the area of sustainability” and a Sustainability Committee that “meets on a quarterly basis and informs the Board of Directors of the issues approached,” yet it does not extend this governance to its lobbying practices. The company describes its approach to policy engagement, stating that “specialised employees with high skills … actively participate in the development of legislation and in discussion forums” and that Altri’s representatives in CELPA and CEPI “ensure that direct and indirect activities that influence policy are consistent with Altri’s Climate Change Strategy, Policy and Vision,” which provides a concrete process for aligning both direct and indirect lobbying with its climate objectives. However, the disclosure does not specify any review or monitoring procedure, nor does it name a formal body or individual responsible for overseeing lobbying alignment, and we found no evidence of an audit, formal sign-off, or periodic assessment of lobbying positions.	2