Climate Lobbying Index

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	JSL SA’s disclosures indicate a limited governance framework for its lobbying activities, with some general compliance oversight but few specifics on climate-related lobbying alignment. The company’s Government Relations Policy “imposes rules and instructions so that interactions with the government are ethical, transparent and abide by the legislation,” and the Compliance Program is “monitored by the CRC” through “continuous and ad-hoc indicators and actions,” including “mapping and continuous review of compliance risks” every two years. While JSL SA has affirmed a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” it does not disclose a targeted policy or detailed review process for aligning climate lobbying efforts, nor does it identify an individual or formal body responsible for overseeing how its lobbying advances its climate commitments. The described materiality process—conducted biennially with “validation by senior leadership”—speaks to the prioritization of sustainability topics broadly but offers no clear mechanism for monitoring and managing direct or indirect climate advocacy. Overall, the evidence points to general compliance measures for government relations but no dedicated governance process for climate lobbying. View Sources	1

Overall Assessment

Analysis

Score

Limited

JSL SA’s disclosures indicate a limited governance framework for its lobbying activities, with some general compliance oversight but few specifics on climate-related lobbying alignment. The company’s Government Relations Policy “imposes rules and instructions so that interactions with the government are ethical, transparent and abide by the legislation,” and the Compliance Program is “monitored by the CRC” through “continuous and ad-hoc indicators and actions,” including “mapping and continuous review of compliance risks” every two years. While JSL SA has affirmed a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” it does not disclose a targeted policy or detailed review process for aligning climate lobbying efforts, nor does it identify an individual or formal body responsible for overseeing how its lobbying advances its climate commitments. The described materiality process—conducted biennially with “validation by senior leadership”—speaks to the prioritization of sustainability topics broadly but offers no clear mechanism for monitoring and managing direct or indirect climate advocacy. Overall, the evidence points to general compliance measures for government relations but no dedicated governance process for climate lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	JSL SA gives a partial picture of its climate-policy advocacy. It identifies two specific policy arenas it engages on – the creation of a national “Mercado Brasileiro de Carbono” and Brazil’s position in the international negotiations on Article 6 of the Paris Agreement – indicating some clarity about the issues it lobbies. The company explains that it acts mainly through the “Posicionamento Empresários pelo Clima” initiative and other private-sector coalitions, describing collaboration with peers to shape “políticas públicas relacionadas às mudanças climáticas” and to present positions to the Brazilian government, but it does not spell out the concrete lobbying tools (such as meetings, submissions or letters) or name particular ministries, legislators or officials it addresses. The stated objectives remain general—support for a transition to a low-carbon economy, alignment with the 1.5 °C goal and endorsement of carbon pricing—without detailing precise legislative changes, targets or timelines it seeks. Overall, the disclosure provides some insight into what the company is lobbying for and the broad channel it uses, yet leaves important gaps on specific methods, targets and desired policy outcomes.	1

JSL SA

Lobbying Transparency and Governance