Naturgy Energy Group SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Naturgy Energy Group provides a very detailed picture of its climate-policy lobbying. It names several specific files it has acted on, including the European Commission’s revision of the EU Emissions Trading System for 2021-2030, the “DG Energy consultation on its Renewable Energy Strategy Post-2020,” Spain’s ADAPTA adaptation initiative, and the “National Carbon Reporting Initiative” led by the Spanish Office of Climate Change, as well as earlier energy-efficiency legislation. For each of these, the company explains how it intervened: it submitted input to the DG Energy consultation, “took an active role in the decision-making process” of the ADAPTA programme, and attended workshops and seminars organised by the Spanish Office of Climate Change to shape the carbon-reporting scheme, thereby clearly identifying both the mechanism (consultations, workshops, decision-making fora) and the policymaking targets (DG Energy, Spanish Office of Climate Change, European Commission). Naturgy is equally explicit about the results it is seeking, advocating for “consistent, market-based approaches” in renewable-energy policy, stating that “specific support can be phased out” as technologies mature, preferring the “EU ETS to drive the deployment of low-carbon generation,” pressing for a carbon price that “enables coal-to-gas switching,” and using carbon-reporting rules to set reduction or compensation plans while emphasising that “risk management and climate change adaptation are key.” This combination of clearly identified policies, mechanisms and targets, and specific desired policy outcomes demonstrates a comprehensive level of transparency in the company’s climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Naturgy has established a foundational governance framework for its climate-related policy engagement through its “Global Policy on Institutional Relations,” which applies to “all interactions with authorities, public officials and political parties, carried out directly or through associations, foundations or other third parties.” In 2020 it undertook a review to “analyse the position in these areas of the main entities in which the company participates” and found that none were misaligned with its climate commitments. During 2021, it has been “updating its Institutional Relations Policy, which, once approved, will incorporate verification requirements regarding positioning in the fight against climate change, as a prior step to joining new associative entities,” making “participation in entities or alliances with third parties conditional upon their alignment with the climate policies emanating from the Paris Agreement.” These measures are reinforced by a public commitment within its Environmental Policy to “promote, directly and through alliances with other actors, climate policies aligned with the Paris Agreement, ensuring permanence only in the trade associations that meet this criterion and publish an annual list of them.” However, the company does not disclose how these verification requirements will be operationally implemented or monitored, offers no details on governance of its direct lobbying activities, and provides no indication of a specific individual or formal body responsible for overseeing alignment of its lobbying with climate objectives.	2