ERG SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	ERG SpA provides extensive, concrete detail on every dimension of its climate-policy lobbying. It identifies a wide range of specific measures it has tried to influence, including Italy’s “Legislative Decree n.199/2021,” the “Italian Simplification Decree 2021,” the EU “Fit for 55” and “REPowerEU” packages, the UK “Connection and Use of System Code CMP315/375,” and Italy’s “Decree-Law 181/2023 (DL Energia Bis),” as well as revisions to RES-support guidelines and carbon-related taxation proposals. The company also explains how it lobbies and who it targets: it details direct hearings before the Italian Chamber of Deputies, “virtual/via Teams” meetings with the Scottish Government, Ofgem, BEIS, HM Treasury and the UK Climate Change Committee, regular participation in “energy and environmental policy working groups,” and action through trade associations such as Confindustria, Elettricità Futura, ANEV, WindEurope and SolarPower Europe; it names institutional counterparts, including “the GSE, the Ministry for the Environment and Energy Security, and the Ministry of Economy and Finance.” Finally, ERG is explicit about the outcomes it seeks, advocating for “a common and simplified framework to guarantee fast authorization for repowering plants,” for renewable auction tariffs that “reflect the dynamics of greenflation,” for the “radical downsizing of authorisation procedures for repowering wind and solar power plants,” for continuation of RES auctions and Carbon Contracts for Differences, and for reforms to the TNUoS charging methodology that would end credits for fossil-fuel generators. This level of specificity on policies, mechanisms and desired results demonstrates comprehensive transparency in the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	ERG SpA provides limited detail on its lobbying governance processes. It indicates that “we adopted an in-house control system based on procedures integrated into the Organisational Model (pursuant to Italian Legislative Decree 231/01 as amended) and supported by a specific system of sanctions” to govern its relations with institutional stakeholders and enforces a policy stating that “no direct or indirect contributions may be paid…to political parties, movements, committees, political organisations, or trade unions.” Its Code of Ethics mandates that “all relationships and contacts with public institutions…shall be managed by the business units formally in charge of keeping contacts with those institutions” to promote transparency. The company asserts that “all the engagement activities with our stakeholder…are coherent with the Paris Agreement” and outlines various methods of influencing policy, including participation in trade-association bodies and “legitimate lobbying activities directly or in association with other energy operators.” However, ERG SpA does not disclose any specific individual or formal body responsible for overseeing or reviewing lobbying alignment, nor does it describe a defined process for monitoring how its direct and indirect lobbying activities are aligned with its climate strategy.	1