Terna Energy SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Terna Energy provides a solid level of transparency around its climate-policy lobbying. It names a range of specific legislative files it has engaged on, including the “EU Taxonomy Regulation,” the “Corporate Sustainability Reporting Directive,” the “Fit for 55 package,” the “EU Green Bond Standard,” and Greece’s “National Plan for Energy and Climate,” making it clear which measures are the focus of its advocacy. The company also explains how and where it lobbies: it “actively collaborated through its Function ‘EU Institutional Affairs’ based in Bruxelles,” worked “in collaboration with the main trade associations of which it is a member (ENTSO-E; Sustainable finance corporate forum),” and produced “position papers on the most relevant measures” for EU policymakers, showing both direct engagement with EU institutions and indirect engagement via industry associations. On policy positions, Terna Energy states that it “support[s] with no exceptions” the Corporate Sustainability Reporting Directive and the EU Green Bond Standard and expresses overall support for the Fit for 55 package and the national energy and climate plan, demonstrating clear—if largely affirmative—outcomes it seeks, even though it does not always spell out detailed amendments or quantitative targets. Together, these disclosures demonstrate strong, though not exhaustive, transparency across policies lobbied, mechanisms used, and outcomes sought.	3

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Terna Energy SA establishes a multi-layered governance process to align its lobbying with its climate strategy. It explains that "We examine very carefully through a due diligence process the trade associations we engage with. The due diligence is being performed by our Legal department," demonstrating formal oversight of its indirect lobbying, and allocates "the monitoring of legislative activities and regulations (including the regulation on climate change)" to specific functions within its Department of Institutional Affairs for direct engagement review. Since 2019, Terna’s Brussels Office has engaged "in a structured and coordinated way" with European institutions and bodies such as ENTSO-E to ensure consistent participation and dialogue on the energy transition. The company also confirms a public commitment "to conduct [its] engagement activities in line with the goals of the Paris Agreement." However, Terna does not disclose a board-level or named executive responsible for reviewing its lobbying alignment, nor does it reference a dedicated climate-lobbying policy document, an independent audit or published report evaluating its climate-related advocacy, which constrains a full transparency and accountability assessment of its governance framework.	3