Neoenergia SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Neoenergia SA provides an unusually detailed picture of its climate-policy lobbying. It cites a suite of identifiable bills and laws it has worked on – including “PL 412/2022” and “PL 528/21” for a regulated carbon market, “Bill 5829/2019” on distributed generation, “Bill 576/2021” on offshore energy, “Bill No. 725/2022” on hydrogen, and the implementation of “Law No. 14,120/2021” – clearly showing where and when it intervenes. The company also spells out how it engages. It describes participation in “discussions, forums, technical workshops” within the Climate, Energy and Sustainable Finance Thematic Chamber of the Brazilian Business Council for Sustainable Development (CEBDS), direct meetings by its Vice-President for Regulation with federal ministries, formal submissions to “Public Consultation No. 118 of 21/01/2022,” and the signing of memoranda of understanding with state governments such as Pernambuco and Ceará to craft green-hydrogen rules. Named targets include the Ministry of Economy, the Ministry of Development, Industry, Commerce and Services, and state secretariats, demonstrating clarity about who is being lobbied. Neoenergia is equally explicit about the results it seeks, advocating “carbon pricing as a way to accelerate mitigation actions for the decarbonization of the Brazilian economy,” supporting an emissions-trading model rather than a voluntary market, opposing the creation of a market “via decree” because it would create “legal uncertainty,” and pressing for legislation that will “regulate the insertion of hydrogen as a source of energy in Brazil.” It links these positions to broader objectives such as achieving carbon neutrality by 2050 and universalising access to clean energy. Altogether, the company offers comprehensive transparency across the policies it lobbies, the mechanisms and targets it uses, and the specific outcomes it is pursuing.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Neoenergia discloses a broad commitment to conduct its public-policy engagement in line with its climate objectives but provides little insight into the mechanisms that would enforce this alignment. The company notes that “the October 2021 Iberdrola Climate Action document, available on the website, presents how the Group, of which Neoenergia is a part, adheres to the Paris Agreement, and defines its objectives and strategies in line with these” and claims that “for this, it has a robust governance system and specific policies directing the Group's actions.” It adds that its Climate Action policy is based on “involving all Interest Groups in its Climate Action strategy, aligned to the 1.5ºC limit” and that the business “participates in activities with stakeholders such as governments, associations, sectoral organizations and other public and private institutions… that may contribute to the fight against climate threats.” While these statements indicate an intention to align lobbying with climate goals, the disclosure does not explain how the purported “robust governance system” functions—there is no description of review cycles, escalation or corrective actions, trade-association alignment checks, or an identified board committee or executive accountable for overseeing lobbying activities. Consequently, the evidence shows only a high-level commitment rather than a clearly articulated governance process for managing and monitoring climate-related lobbying.	1