Banco BTG Pactual SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Banco BTG Pactual gives a partial view of its climate-policy lobbying. It acknowledges working on Brazil’s emerging carbon-market legislation, noting that “Brazil is in the process of creating a law that regulates its national carbon market” and that it took part in discussions on “The Brazilian Central Bank's climate stress test norm,” but it does not cite bill numbers or other identifying details for the carbon-market bills. The bank outlines the channels it uses – “research and discussions on the topic, analysis and comparability of the existing bills, participation in webinars and working groups,” including contribution to a Febraban working group – yet it never names the specific government departments or officials it addresses. On objectives, it states that its engagement is “aligned with the Paris Agreement” and that it is “sharing expertise and suggesting approaches to this regulatory demand,” but it offers no concrete policy changes, amendments or quantitative targets it is pursuing. Together, these disclosures show only limited transparency about the policies, methods and outcomes of the bank’s climate-related lobbying.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Banco BTG Pactual SA indicates that it “participates in self-regulating entities such as Febraban and Anbima in climate related working groups, discussing regulations and laws for financial institutions” and has a public commitment, answering “Yes” to conducting its engagement activities in line with the goals of the Paris Agreement. However, the company does not disclose any formal governance process for its lobbying or policy engagement—such as a defined review or monitoring procedure, a named individual or committee overseeing alignment, or mechanisms to enforce its climate strategy in direct or indirect advocacy activities.	1