CPFL Energia SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	CPFL Energia provides a highly detailed picture of its climate-policy advocacy. It names multiple concrete initiatives it works on, including federal bills “PL 232/2016” and “PL 1917/2015” to remodel Brazil’s power sector, the public-consultation for the “Brazilian Carbon Market,” support for the “Task Force on Climate-related Financial Disclosure (TCFD)” recommendations, the state-level “São Paulo Agreement,” and the wider push for a national carbon tax and cap-and-trade scheme. The company also explains how it tries to influence these measures. It reports participating in public consultations, joining simulations run by FGVces, sitting on the “PMR Advisory Council” and “PMR working group,” and, as it puts it, “actively participat[ing] in the discussions with the Energy Research Company (EPE), the Ministry of Finance, FMBC, among others, with the PMR (World Bank).” These references identify both the engagement tools and the specific government or multilateral bodies targeted. CPFL is equally explicit about what it wants to achieve: it seeks the “formal acceptance” of the TCFD recommendations by G20 nations, backs “the creation of a cap and trade scheme in Brazil” to price carbon cost-effectively, supports rules that would “increase the competitiveness of renewable power generation” and give consumers granular consumption data, and uses the São Paulo Agreement to drive voluntary emissions cuts consistent with keeping warming below 2 °C. By clearly naming the policies, describing the mechanisms and targets of engagement, and spelling out the concrete legislative or regulatory outcomes it is advocating, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	CPFL Energia discloses only a high-level commitment that its "engagement activities are consistent with your overall climate change strategy" and explicitly states that "we are committed to the goals of the Paris Agreement and to the need to limit the increase in the average global temperature to 1.5°C, with the consequent reduction in GHG emissions" and confirms "Yes" to having "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement." While this signals an intention to align advocacy with climate objectives, the evidence does not describe any concrete governance mechanisms—there is no reference to who reviews or approves lobbying positions, how direct or trade-association lobbying is monitored, or what corrective actions are taken if misalignment is found. Consequently, the disclosure shows only a limited governance approach centred on a stated commitment, and the company does not disclose oversight structures, monitoring procedures, or responsible individuals or bodies for lobbying alignment.	1