Telecom Italia SpA/Milano

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Telecom Italia provides a very full picture of its climate-related lobbying. It names multiple concrete legislative files it works on – the EU Green Deal, the “Fit for 55” package (including the Energy Efficiency Directive and the Taxonomy Regulation) and Italy’s National Recovery and Resilience Plan – as well as national measures connected to those files, allowing readers to identify exactly which rules it seeks to influence. The company is equally explicit about how and where it lobbies: it holds “meetings with members of parliamentary committees” in Rome, participates in parliamentary hearings, takes part in “public consultations and workshops” with the European Commission and other EU institutions, maintains a Brussels representative office, and also engages indirectly through trade associations such as “ETNO, GeSI, GSMA”; it even discloses dialogue in Brazil with government, Congress and regulatory authorities. Finally, it spells out the outcomes it is pursuing, for example supporting emission-reduction targets of “-55% by 2030” and “climate neutrality by 2050,” seeking amendments to the Energy Efficiency Directive to ensure “technical and legal feasibility” for the ICT sector, and promoting “adoption of energy efficient solutions,” “deployment of advanced telecommunications networks,” and the “inclusion of the ICT sector in the scope of the Community Guidelines on State aids for environmental protection and energy.” By providing clear policy references, detailed mechanisms and named policy goals, the company demonstrates a high level of transparency in its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Telecom Italia outlines a defined governance framework to ensure its lobbying aligns with its climate commitments by embedding climate strategy at the corporate level and establishing clear departmental and executive oversight. It explains that “Climate Change policy and strategy are defined at corporate level and spread across the two country of operations and all business units,” formalized in the TIM Group Environmental Policy, and states that “coordination on public positions vis-à-vis company’s stakeholders and in particular policy makers is guaranteed by the internal Public Affairs, Regulatory Affairs, and Institutional Communication Departments.” The company assigns responsibility for direct policy engagement to these departments “in close cooperation with the executive managers of the areas involved, such as the Head of Sustainability and the Head of Real Estate,” thereby naming specific individuals who review and approve positions. It also addresses indirect lobbying by noting that “those actions may be coordinated ... with national and international trade associations such as Confindustria, ETNO, GSMA and GeSI.” While this indicates strong governance over both direct and indirect lobbying channels and clear oversight roles, Telecom Italia does not disclose a formal monitoring schedule, periodic review cycle, or external audit mechanism to assess ongoing alignment with its climate transition objectives.	3