Azul SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Azul SA offers a very detailed picture of its climate-related lobbying. It names multiple specific pieces of Brazilian legislation and programmes it seeks to influence, including the “ProBioQAV project,” the “Fuel of Future Program,” “Law 13,576/17,” “PEC 15/2022,” “PL 528/2021” and “Ordinance No. 514/2018,” making it easy to identify the exact policy files on which it engages. The company also explains how it lobbies and who it targets, citing “rounds of conversations with regulators,” participation in “working groups that also involve the associations we participate in,” and representation through bodies such as IATA, ALTA and CEBEDS, while naming concrete counterparts like “SAC, ANAC, DECEA, INFRAERO, airport concessionaires” as well as ministers and parliamentarians. Finally, it is explicit about the results it wants: it seeks to “propose measures to increase the use of sustainable and low-carbon fuels,” “introduce sustainable aviation fuel into the Brazilian energy matrix… through the creation of laws and infra-legal regulations,” oppose imported European SAF rules that would “hinder Brazil’s potential SAF production routes,” and secure the “granting of tax incentives aimed at promoting the development of the policy for the use of biofuels” to close the cost gap with fossil fuels. Together, these disclosures demonstrate a high level of transparency across the policies lobbied, the mechanisms employed, and the concrete outcomes the company pursues. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Azul SA has established a governance process for its climate-related policy engagement that is led by its board of directors and coordinated across specialized departments, but it does not provide a clear mechanism for managing direct lobbying activities or any formal review of its lobbying alignment. The company explains that “Azul's board of directors oversees the corporate approach to managing GHG emissions, through the review and guidance of the company's strategy and annual budgets, in which the company's CFO also participates in the supervision,” and states that “environmental policy and regulatory issues, including climate change, are coordinated by the legal department, corporate sustainability department and institutional relations department.” It further clarifies that “these teams oversee the company's climate change strategy and implementation and work to ensure that engagement activities with the trade associations we participate in are consistent across all operations,” indicating a process to align its indirect lobbying via trade associations. However, the company does not describe how its direct advocacy efforts are monitored or managed, nor does it publish a dedicated lobbying audit or designate a single individual or committee solely responsible for ensuring climate lobbying alignment. 2