Haci Omer Sabanci Holding AS

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Sabancı Holding provides a moderate level of transparency about its climate-policy lobbying. It identifies two specific policy areas it has acted on – Türkiye’s emerging emissions-trading scheme and the Capital Markets Board (CMB) regulation that would make climate-related disclosures mandatory for listed companies – and situates both within the Turkish regulatory framework. The company is more detailed when describing how it engages: it explains that it “participated in Türkiye’s first Climate Council in February 2022” convened by the Ministry of Environment, Urbanization and Climate Change, that it “provided our comments on the draft climate regulation of Türkiye,” and that it gave “comments and support for the regulation” issued by the CMB. These statements outline three concrete mechanisms (formal council participation, written comments on draft rules, and feedback on a specific reporting regulation) and name the public bodies they targeted, demonstrating a high degree of procedural openness. However, the company only expresses broad positions – for example that it supports “mandatory climate-related reporting” and “ETS mechanisms” “with no exceptions” and that its activities are aligned with the Paris Agreement – without setting out the precise legislative changes, quantitative targets, or other measurable outcomes it seeks. The absence of such detail limits insight into its policy objectives even though the channels and targets of engagement are clear.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Haci Omer Sabancı Holding AS appears to have a structured board-level oversight on sustainability and public policy, but discloses limited information on how it governs climate-related lobbying. The company reports that “a Board Level Sustainability Committee was established, which is formed and governed by independent Board Members of Sabancı Holding,” and that “the Committee meets in ordinary session at least twice a year,” with its minutes submitted to the Board. Among its wide remit, the committee includes “overseeing and guiding public policy engagement” and regularly discusses “local and global developments related the climate emergency,” approving interim targets and KPIs for its net-zero roadmap. However, we found no evidence of a specific process or policy to align the company’s lobbying—direct or via trade associations—with its climate objectives, nor any disclosure of how such engagement is monitored, managed, or enforced, and no named individual or published audit overseeing lobbying activities.	1