Galp Energia SGPS SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Galp Energia SGPS SA has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly identified specific climate policies it has engaged with, including the "Fit-For-55 package," "revision of the EU-ETS," "RED II," "FuelEU," "REFuelEU," and the "Critical Raw Materials Act," providing detailed information about the focus and geographical scope of these policies. Galp has also disclosed its position on these policies, such as expressing "Support with minor exceptions" for the Critical Raw Materials Act and suggesting improvements related to "the protection to the raw materials extracted within EU territories." Furthermore, Galp provides detailed information about its lobbying mechanisms, stating that it "participates actively in public consultations and in collaborative groups, conferences and forums created by the European Commission" and "promote[s] meetings with the European institutions." It identifies specific policymaking targets, such as "DGEG, APA, National Portuguese Government and European Commission," showcasing clarity in both the mechanisms and targets of its lobbying activities. Finally, Galp has been transparent about the outcomes it seeks, including proposals that "more directly impact the company's activities," such as revisions to the EU-ETS and other Fit-For-55 package elements, and expressing support for the "Critical Raw Materials Act" while proposing "improvements on some topics covered in this legislation." This demonstrates a clear articulation of desired policy changes and alignment with its climate objectives, reinforcing its commitment to transparency in climate lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Galp demonstrates a comprehensive climate lobbying governance process, showcasing robust mechanisms to ensure alignment of engagement activities with its climate change strategy. The company explicitly states, "All our associations are analyzed according with these criteria and the monitoring report is annually updated and publicly available," indicating a thorough monitoring process for indirect lobbying through industry associations. Furthermore, Galp has published a detailed lobbying audit, as evidenced by its "2022 Report" on participation in industry associations, which is publicly accessible. The company emphasizes alignment with international climate goals, noting that "Galp, jointly with Industry Associations, supports the development of strategies aligned with the international community's goals, mainly those regarding the energy transition and carbon neutrality." Additionally, Galp has identified responsible parties and processes for oversight, mentioning that "future association membership" is chosen based on "criteria aligned with the Paris Agreement and the European Climate Law in accordance with Galp's strategy for the decade 20-30." This reflects a clear governance structure and accountability measures for both direct and indirect lobbying activities, ensuring alignment with climate objectives.	4