Sonae SGPS SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Sonae SGPS is highly transparent about its climate-policy lobbying. It names multiple specific files it has worked on, including the European Green Deal, the Fit for 55 Package (with particular reference to the EU ETS and the Carbon Border Adjustment Mechanism), the REPowerEU plan, and the revision of the Alternative Fuels Infrastructure Directive, making it clear which pieces of legislation it seeks to influence and in what jurisdiction. The company also explains in detail how it engages: it contributes expert papers through the European Roundtable for Industry, submits responses to European Commission public consultations, “actively participat[es] in the construction of responses from the associations in which it participates,” and circulates position papers to EU decision-makers—thereby disclosing several distinct mechanisms and identifying EU policymakers as the targets. Finally, Sonae sets out the concrete outcomes it pursues, such as “mandating energy audits” under the Energy Efficiency Directive, accelerating deployment of renewable energy and carbon-storage projects by putting in place “the right incentives and framework,” and, for CBAM, extending the mechanism to more sectors, covering indirect emissions, and establishing “a fair and verified calculation methodology for carbon content.” By describing the policies, the channels of influence, and the exact changes it seeks, the company provides a comprehensive picture of its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Sonae SGPS has established a defined process to ensure that its direct engagement with policymakers is aligned with its climate strategy by stipulating that “all processes implemented are closely supervised and approved by the Board of Directors, to ensure that engagement made with policymakers and other stakeholders is consistent and aligned with the Climate Change Strategy”. It further assigns oversight to a named body, stating that the “Sustainability Advisory Group also ensures that the common approach to multiple climate engagement activities across business divisions and geographies is consistent with our climate change strategy”, with the CEO and Chairman attending all quarterly meetings. However, while the company describes “dedicated teams responsible for addressing legal and regulatory areas in corporate governance and public affairs”, it does not disclose how it governs its indirect lobbying through trade or industry associations or any criteria for reviewing association positions against its climate goals.	2