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Cielo SA does not disclose any governance processes specific to lobbying or climate-related policy engagement. When asked, “Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […]” the company answered, “No, and we do not plan to have one in the next two years.” Its policy details roles for an “Executive Corporate Governance Superintendency”, a “Sustainability Committee” tasked to “Propose and monitor the execution of projects that improve the Company’s sustainability practices”, and a “Board of Directors” mandated to “Promote sustainability topics within the Company’s business processes, addressing social, economic, good corporate governance, and environmental issues, including those related to climate change.” However, we found no evidence of any oversight, sign-off, or alignment mechanisms for direct or indirect lobbying activities, nor any designated individual or body charged with ensuring that lobbying aligns with the company’s climate or sustainability objectives, and no reference to managing trade association positions or reviewing lobbying efforts against its policies.
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