SM Investments Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	SM Investments Corporation provides only limited insight into its climate-related lobbying activities. It names one specific piece of legislation it is engaging with—the review of House Bill 7705, which aims to promote a low-carbon economy and ensure fair implementation of carbon-emission regulations—but gives no indication that this is the entirety of its lobbying portfolio or that other relevant bills are not being addressed. The company notes participation in an educational forum organised by the Carbon PH Coalition and involvement in the legislative review process, yet it does not clarify whether its advocacy involves written submissions, meetings, or other direct interactions, nor does it identify which government bodies or policymakers it targets. Finally, while it signals a broad objective of supporting environmental conservation and helping the country meet national climate targets through the adoption of House Bill 7705, it does not articulate more granular or measurable policy outcomes it is seeking. The absence of additional named policies, clearly described lobbying channels, and detailed policy positions means the overall transparency of its climate lobbying remains limited.	1

Lobbying Governance

Overall Assessment	Comment	Score
None	SM Investments Corp reports that “The ExeCom performs an oversight function on material ESG issues relevant to the Company” and that this body is “assisted by the Climate Change Steering Committee, chaired by the CEO, which provides oversight on climate risks and opportunities,” with plans to “establish a Climate Change Working Group with senior management and technical staff, which presents recommendations to the Board.” However, the company does not disclose any governance mechanisms, structures, or processes for overseeing or aligning its lobbying activities—there is no mention of how its direct lobbying or engagement through industry associations is managed, no policy commitments for aligning political advocacy with its climate objectives, and no identified individual or committee responsible for lobbying oversight. We found no evidence of any internal processes to govern lobbying alignment with its ESG or climate goals.	0