Gerdau SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate Gerdau SA provides clear identification of several climate-related policies it has engaged with, naming the “Brazilian Carbon Marketing” under the National Policy on Climate Change, “Canada’s Federal Output-Based Pricing System Regulation,” the “Ontario Performance Standards regulation,” and “USEPA Regulations.” However, while the company notes that it engages “through IABR, and Brazilian National Confederation of Industry (CNI)” to participate in discussions on the Brazilian Carbon Marketing and refers to compliance steps such as “reporting yearly emissions” and “third-party verification” under Canadian and U.S. frameworks, it does not detail how these engagements occur or specify which government bodies or policymakers are targeted. Gerdau also expresses an ambition to be “carbon neutral by 2050” and advocates for “access to special local, national or transnational financing lines from public or private sources” to support low-emission steelmaking, but it stops short of outlining any concrete legislative changes, amendment proposals, or quantified policy outcomes. This set of disclosures indicates moderate transparency in its climate lobbying efforts. 2
Lobbying Governance
Overall Assessment Comment Score
Moderate Gerdau discloses that a “corporate Institutional Relations department, in addition to teams specialized in the subject, such as the Environment and Engineering team and an ESG Squad” is responsible for engagement, and that “they jointly assess the consistency of the actions with the Company's policy,” indicating an internal mechanism that reviews whether its policy advocacy aligns with company positions. The same passage notes that these teams oversee involvement in external bodies such as “CNI, IABR, Worldsteel, and FGV's Business Initiatives,” showing some attention to the alignment of indirect lobbying through trade associations. While this demonstrates a defined process and identifies a formal internal body charged with oversight, the company does not disclose how often the assessments occur, the criteria used, any escalation to the board or senior executives, or the way direct lobbying is monitored and corrected, nor does it publish the outcomes of these reviews; thus, transparency and depth of the governance framework remain limited. 2