Snam SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Snam SpA has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has explicitly named specific climate policies and regulations it has engaged with, such as the "Gas and Hydrogen Decarbonization Package," "Fit for 55" (including RED III, EU ETS, CBAM, AFIR), "Heavy Duty Vehicles Regulation," "Energy Performance of Building Directive," "State Aid rules," "REPower EU," and the "Green Deal Industrial Plan." At the national level, it has identified decrees like the "National Decree implementing RED II" and "National Decree setting out support to Biomethane production." These disclosures provide detailed insights into the policies engaged with. Snam has also been transparent about its lobbying mechanisms, detailing its participation in public consultations, parliamentary hearings, and over 150 meetings with national and local institutions, as well as its registration in the EU Transparency Register. The company has identified specific targets, such as the Italian authority Arera and European and international institutions, showcasing a clear and structured approach to its lobbying efforts. Furthermore, Snam has outlined specific policy outcomes it seeks, including enhancing EU carbon pricing mechanisms, creating the EU Social Climate Fund, and advocating for ambitious targets and efficient subsidy schemes for hydrogen and biomethane production. It also aims to develop a harmonized regulatory framework for CO2 transport, utilization, and storage. These disclosures reflect a high degree of clarity and detail, demonstrating Snam's commitment to transparency in its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Snam has demonstrated a robust and comprehensive approach to aligning its lobbying activities with its climate goals. Despite some evidence that only referenced broader climate change strategies and minimal details on governance, a more detailed disclosure clearly shows that the company has established structured oversight and monitoring mechanisms for both direct lobbying efforts and memberships in relevant associations. Snam's approach is evidenced by statements such as its Board of Directors "maintain oversight of the company's climate resilience and governance," and the description of its internal processes where "an evaluation is carried out by the internal competent departments" before joining any association, followed by an "annual monitoring activity... to guarantee the alignment of the association's memberships with the business objectives." Additionally, the company publishes detailed reports such as its "Climate Change Report" and provides "full disclosure of all the amount spent for engagement and lobby activities at EU level" via its registration in the EU Transparency Register. These measures, including its internal policy that "regulates in detail the management of relations with the Public Administration," underline a clear commitment to ensuring that both direct and indirect lobbying activities are in line with its climate strategy, indicating strong governance in this area.	4