Petroleo Brasileiro SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong Petróleo Brasileiro SA provides a high level of transparency around its climate-related lobbying. It names three distinct Brazilian initiatives it has worked on—“Bill 576 of 2021, which provides the use of Union assets for offshore energy generation,” “Bill 1425/2022, which regulates the … permanent storage of CO2,” and the forthcoming “regulation of the carbon market in Brazil”—clearly identifying the subject matter, jurisdiction and stage of each measure. The company also explains how it seeks to influence these proposals, noting that it acts “directly and through associations with the Federal Senate” and works with industry bodies such as IBP, CEBDS and CNI when engaging “the National Congress and other interlocutors of the federal public power.” Finally, it is explicit about the changes it wants: for Bill 576 it aims to “defend … adjustments in the text … aiming at the simplification and objectivity of these criteria” and to ensure offshore wind rules “consider local specificities and the need to ensure investment attractiveness”; for Bill 1425/2022 it seeks references to international CCUS experience and the “possibility of vertical action” across capture, transport and storage; and for the carbon-market law it advocates “clear rules for the transaction of emission permits,” a “national registry system,” limited but certified offset use, and “social and environmental safeguards for local communities.” This detailed disclosure of policies, mechanisms and desired outcomes demonstrates strong transparency, although the company identifies only two distinct lobbying channels (direct engagement and work through associations). 3
Lobbying Governance
Overall Assessment Comment Score
Limited Petroleo Brasileiro SA relies on its ESG oversight bodies and climate forums to guide its engagement activities but provides no explicit governance framework for lobbying or policy advocacy alignment. The company explains that The monitoring of the ESG commitments and goals disclosed in our SP 2025-2029 is carried out by the Health, Safety, and Environment Committee (local acronym is CSMS), which is responsible for advising the BoD on the establishment of policies and guidelines related to ESG, including strategic management of HSE (Health, Safety, and Environment), climate change, transition to a low-carbon economy, social responsibility, among other subjects, and that we built a governance with discussion and deliberation forums that perpasses all levels of the company, all of them with the participation of Climate Change Executive Management, showing a structured review process. It further states that we evaluate our engagement alignments, and that some types of engagement in our participation in OGCI count on meetings of internal participants to discuss relevant ongoing issues and activities, indicating a commitment to monitor consistency with Paris Agreement goals. However, we found no evidence of a named individual or dedicated committee tasked specifically with overseeing lobbying activities, nor any criteria for assessing or exiting trade or industry associations whose positions might conflict with the companys climate objectives. 1