Aena SME SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Aena SME SA provides a high level of transparency around its climate-policy lobbying. It names a broad suite of individual measures it has worked on, including EU initiatives such as the “Fit for 55 package” (covering the Alternative Fuels Infrastructure Regulation, ETS for Aviation and the Energy Taxation Directive), the “Refuel Aviation Regulation,” EU Directive 2014/94 on alternative-fuel infrastructure, the Spanish “Sustainable Mobility Law,” the “Climate Change Law,” the “Integrated National Energy and Climate Plan 2021-2030,” and regional air-quality plans for Catalunya and the Community of Madrid (“Plan Azul+”). The company also discloses how it seeks to influence these files: it submits “allegation reports” and “position papers,” presents amendments that have been “agreed with members of the European Parliament,” participates in the “Interministerial Group for the coordination of the framework of national action of alternative energies for transport,” and works directly with specific governmental bodies such as the Ministry of Transport, Mobility and Urban Agenda and “La Generalitat de Catalunya.” These descriptions clearly identify both the mechanisms used and the policymaking targets. Finally, Aena is explicit about the policy outcomes it pursues, for example advocating “mandatory national targets for the deployment of sufficient alternative fuels infrastructure,” requesting “flexibility mechanisms” in Refuel EU, and helping craft measures in the Catalunya air-quality plan such as “Technological renewal of vehicles and equipment” and “Aeronautical operation optimization and improvement.” It notes that it “supports [the Fit for 55 files] with no exceptions” and that the proposed positions have been checked for alignment with the Paris Agreement, demonstrating clarity about both the substance and intent of its lobbying. 4
Lobbying Governance
Overall Assessment Comment Score
Limited Aena provides only a brief indication that it tries to keep its policy advocacy consistent with its climate goals, noting that it “participates in several processes to ensure consistency of all activities with the climate change strategy of the company, both at a EU and national level” and that this includes “monitoring and participation in the processes of consultation of new legislation through the ACI (Airports Council International)” as well as the “elaboration of a position paper on Refuel EU”. This shows the company recognises the need to align its direct and indirect lobbying with its climate strategy. However, the disclosure stops short of describing a structured governance process: no procedure is given for how lobbying positions are reviewed or approved, there is no reference to regular audits or criteria for assessing trade-association alignment, and no specific individual or committee is tasked with overseeing lobbying activities. The Sustainability and Climate Action Committee is described as responsible “to know, promote, guide and supervise the Company’s objectives, action plans, practices and policies in environmental and social matters” and to “review… the Climate Action Plan”, but these powers relate to operational sustainability rather than to lobbying or public-policy engagement. Because the evidence contains only a general commitment to consistency and lacks detail on oversight mechanisms, monitoring frequency, or accountability for lobbying alignment, this indicates limited governance rather than a well-defined process. 1