B3 SA - Brasil Bolsa Balcao

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	B3 SA – Brasil Bolsa Balcão provides a highly detailed picture of its climate-policy lobbying. It lists several concrete Brazilian measures it has engaged on, including the National Biofuels Policy RenovaBio created by Law 13.576/2017 (with the associated CBIO regulation under Decree 9,888/2019 and Ordinance 419/2019), “Law Project 528/2021 and Law Project 412/2022” that would set up the Brazilian Emission Reductions Market, and the Securities and Exchange Commission’s “Resolution 59” that replaces Instruction 480 and tightens climate-related disclosure rules. The company is equally explicit about how and where it lobbies: it “provided contributions to the new Securities and Exchange Commission (CVM) Resolution 59,” “participated in the meeting held by the Brazilian Ministry of Mines and Energy with representatives of the Ministry of Economy, the Central Bank and the Ministry of Agriculture, Livestock and Supply” to shape the CBIO rules, held more than 40 further meetings with agencies such as the Ministry of Science and Technology and the World Bank, and pursues indirect advocacy through the CEBDS Climate Chamber and the Financial Innovation Laboratory of the CVM. Finally, B3 articulates clear policy objectives—improving climate-change disclosures in the Reference Form, supporting regulation that will “regulate and build the Brazilian Emission Reductions Market,” and enabling CBIOs so that Brazil can lift bioenergy’s share of the energy mix to about 18 % by 2030 in line with Paris commitments—demonstrating transparency about both its positions and the outcomes it seeks. Together, these disclosures amount to comprehensive transparency on the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
None	B3 SA’s description of a “comply or explain” model involves issuers presenting “evidence of adoption of the practice established in the rule” or providing an explanation for non-execution, which “preserves transparency and accountability for the market, allowing access to information on corporate governance and practices so that investors and other stakeholders may engage in dialogue with the issuer’s senior management on ESG matters,” but this mechanism applies to market issuers rather than B3’s own policy-influencing activities. We found no evidence of any internal policy detailing oversight, monitoring, or accountability for either direct or indirect lobbying, nor any named individual or formal body charged with reviewing lobbying alignment. When asked if it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” the company replies, “No, but we plan to have one in the next two years,” indicating no current governance process for climate-related lobbying alignment.	0