Jeronimo Martins SGPS SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Jeronimo Martins SGPS SA has a moderate governance process for its climate-related policy engagement, characterized by dedicated corporate divisions and clear leadership accountability but lacking explicit provisions for direct lobbying alignment. The company explains that “The Corporate Environment Division coordinates, at corporate level, all activities related to the environmental aspects of the Group’s activities, including climate change,” and that this division “issues guidelines and collects information from the Environment Departments of our three geographies,” indicating formal mechanisms to align policy actions. It further highlights that “company representation at international/global trade associations (CGF, EuroCommerce) is conducted at corporate level, by members of the Environmental and Communications and Corporate Responsibility Functional Divisions,” and underscores that “the senior manager responsible for the Corporate Communications and Responsibility Functional Division reports directly to the company’s CEO and is also a member of the Managing Committee,” establishing a named individual responsible for oversight. The company also publicly commits to align its engagement “in line with the goals of the Paris Agreement.” However, we found no evidence of a specific review or sign-off procedure for its direct lobbying activities with policymakers, nor of any third-party audit of its climate lobbying alignment, suggesting that while indirect lobbying is explicitly governed, direct advocacy processes are not clearly defined. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Jeronimo Martins SGPS SA has a moderate governance process for its climate-related policy engagement, characterized by dedicated corporate divisions and clear leadership accountability but lacking explicit provisions for direct lobbying alignment. The company explains that “The Corporate Environment Division coordinates, at corporate level, all activities related to the environmental aspects of the Group’s activities, including climate change,” and that this division “issues guidelines and collects information from the Environment Departments of our three geographies,” indicating formal mechanisms to align policy actions. It further highlights that “company representation at international/global trade associations (CGF, EuroCommerce) is conducted at corporate level, by members of the Environmental and Communications and Corporate Responsibility Functional Divisions,” and underscores that “the senior manager responsible for the Corporate Communications and Responsibility Functional Division reports directly to the company’s CEO and is also a member of the Managing Committee,” establishing a named individual responsible for oversight. The company also publicly commits to align its engagement “in line with the goals of the Paris Agreement.” However, we found no evidence of a specific review or sign-off procedure for its direct lobbying activities with policymakers, nor of any third-party audit of its climate lobbying alignment, suggesting that while indirect lobbying is explicitly governed, direct advocacy processes are not clearly defined.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Jerónimo Martins gives only limited insight into its climate-related lobbying. The company lists its participation in broad sustainability coalitions such as Business for Nature, We Mean Business, the European Climate Pact and the Roadmap for Decarbonisation of the Distribution Sector, but it does not identify any specific climate laws or regulations it has tried to influence, so the actual policies lobbied remain unclear. Likewise, it offers no description of direct or indirect lobbying tools—such as meetings, letters or consultation responses—nor does it name any governmental or legislative targets for such activity. The disclosures do cite high-level aspirations tied to those initiatives, for example supporting decarbonisation and circular-economy goals, yet they do not spell out concrete legislative changes or measurable policy outcomes the company is pursuing. As a result, the company’s reporting reveals only a broad commitment to climate action without transparent detail on what policy changes it seeks, how it seeks them, or with whom.	D