Tubacex SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Tubacex discloses some high-level governance elements that touch on stakeholder engagement and climate-related commitments, but it provides only limited insight into how lobbying itself is managed or aligned. The company affirms that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and states that it “participates in several associations that could influence environmental regulations at national and international levels,” indicating an intention to align external advocacy with its climate goals. Oversight of broad ESG matters sits with the Board-level Sustainability and Good Governance Committee, whose duties include to “"Understand, oversee and assess relations with the different stakeholders"” and whose creation was “approved by the Board of Directors at its meeting held on 16th December 2021.” In addition, a 2023 policy notes that “"the Sustainability and Corporate Governance Committee … will be responsible for monitoring it",” suggesting a formal body has some monitoring role. However, the company does not disclose a specific lobbying or trade-association review process, does not describe concrete mechanisms for checking direct or indirect lobbying alignment, and provides no evidence of publishing a lobbying report or conducting audits. As the disclosure consists mainly of broad ESG governance statements and a general commitment to align engagement with the Paris Agreement, without detailing procedures, monitoring steps, or trade-association actions, this indicates only limited governance over climate-related lobbying activities. View Sources	D

Overall Assessment

Analysis

Score

Limited

Tubacex discloses some high-level governance elements that touch on stakeholder engagement and climate-related commitments, but it provides only limited insight into how lobbying itself is managed or aligned. The company affirms that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and states that it “participates in several associations that could influence environmental regulations at national and international levels,” indicating an intention to align external advocacy with its climate goals. Oversight of broad ESG matters sits with the Board-level Sustainability and Good Governance Committee, whose duties include to “"Understand, oversee and assess relations with the different stakeholders"” and whose creation was “approved by the Board of Directors at its meeting held on 16th December 2021.” In addition, a 2023 policy notes that “"the Sustainability and Corporate Governance Committee … will be responsible for monitoring it",” suggesting a formal body has some monitoring role. However, the company does not disclose a specific lobbying or trade-association review process, does not describe concrete mechanisms for checking direct or indirect lobbying alignment, and provides no evidence of publishing a lobbying report or conducting audits. As the disclosure consists mainly of broad ESG governance statements and a general commitment to align engagement with the Paris Agreement, without detailing procedures, monitoring steps, or trade-association actions, this indicates only limited governance over climate-related lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	The company provides only limited insight into its climate-related lobbying. It does name a single, identifiable policy—the EU Carbon Border Adjustment Mechanism (Regulation 2023/956)—and describes an internal adaptation project and quarterly emissions reporting linked to that regulation, but it does not mention any other specific laws or regulations it tries to influence. It indicates that it works “through sectoral, national, European, and international associations” to shape policy, yet it does not explain whether this involves meetings, letters, formal consultations, or which government bodies or individual officials are approached. Likewise, the discussion of intended outcomes remains high-level: the firm cites corporate goals such as achieving carbon neutrality by 2050, a 60 % emissions reduction by 2030, and establishing a Low Carbon division, but it does not spell out the concrete policy changes it is advocating for or opposing within CBAM or any other framework. As a result, while the disclosure confirms some engagement with climate policy, it lacks the detail needed to demonstrate a clear or comprehensive lobbying strategy.	D