NOS SGPS SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	NOS SGPS SA outlines a governance structure that places “maximum responsibility for the Corporate Sustainability Strategy and associated commitments” with the Executive Committee and identifies the CFO as the Board member with “direct responsibility for all sustainability-related issues, with climate strategy playing a key role.” It notes that the “Corporate Investor Relations and Sustainability Department, delegated by the Executive Committee, is in charge of coordinating the implementation of the strategy” and that its position “within the company structure” as “a top-level department, whose Head reports directly to the CFO” “ensures consistency in climate-policy engagement across the company.” While this demonstrates clear assignment of oversight and a coordinating mechanism to align policy engagement with climate commitments, the company does not disclose any specific process for reviewing or managing the alignment of its lobbying activities—either direct advocacy or through trade associations—nor does it reference audits, formal sign-offs, or procedures to address potential conflicts in external forums. View Sources	C

Overall Assessment

Analysis

Score

Moderate

NOS SGPS SA outlines a governance structure that places “maximum responsibility for the Corporate Sustainability Strategy and associated commitments” with the Executive Committee and identifies the CFO as the Board member with “direct responsibility for all sustainability-related issues, with climate strategy playing a key role.” It notes that the “Corporate Investor Relations and Sustainability Department, delegated by the Executive Committee, is in charge of coordinating the implementation of the strategy” and that its position “within the company structure” as “a top-level department, whose Head reports directly to the CFO” “ensures consistency in climate-policy engagement across the company.” While this demonstrates clear assignment of oversight and a coordinating mechanism to align policy engagement with climate commitments, the company does not disclose any specific process for reviewing or managing the alignment of its lobbying activities—either direct advocacy or through trade associations—nor does it reference audits, formal sign-offs, or procedures to address potential conflicts in external forums.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E