Hellenic Telecommunications Organization SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate Hellenic Telecommunications Organization SA provides a moderate level of transparency about its climate-related lobbying. It names two concrete regulatory processes it engaged in—the BEREC public consultation on environmental reporting and the European Commission’s assessment of environmental indicators for a Code of Conduct covering fixed and mobile telecom networks—clearly identifying the topics and the competent EU bodies involved. The company explains that it participated “through the established processes for public consultation per legislative act as defined by national and EU authorities,” giving one specific mechanism and explicitly naming its targets, BEREC and the European Commission. It also discloses the outcomes it pursued, seeking to improve “the comparability of telecom industry players’ environmental impact and performance” and to support the introduction of “environmental indicators in a Code of Conduct for fixed and mobile telecom networks,” and states that it offered “Support with no exceptions” in line with the Paris Agreement. While the disclosure identifies only a single form of engagement, it nevertheless presents clear information on what the company lobbied for, how it did so, and why. 2
Lobbying Governance
Overall Assessment Comment Score
Strong Hellenic Telecommunications Organization SA articulates that “the consistency between our direct and indirect activities that influence policy and our climate change strategy is ensured through the sustainability governance structure, the decision-making process within the company (key decisions are made or approved by the BoD) but also through the established procedures in the context of the integrated management system,” and it reiterates that “the sustainability governance structure, the decision-making process within the company (key decisions are made or approved by the BoD) but also the established procedures in the context of the integrated management system ensure the consistency between our engagement with stakeholders including policy makers (e.g., in the context of public consultation processes) and our sustainability strategy and commitments.” These disclosures illustrate a defined process for aligning both direct and indirect policy engagement with its climate commitments and identify the Board of Directors as the formal oversight body. The company also confirms a public commitment to carry out engagement activities in line with the Paris Agreement, answering “Yes” to that question. However, we found no evidence of specific monitoring or review mechanisms for its lobbying activities, no criteria for assessing its participation in trade or industry associations, nor any dedicated audit or publicly available report evaluating the alignment of its climate-related lobbying. 3