Athens International Airport SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Athens International Airport provides only limited insight into its climate-related lobbying. It notes that it pursues “sustainability lobbying and advocacy initiatives” through business associations such as CSR Hellas, the SEV Business Council for Sustainable Development and ACI EUROPE, and highlights its CEO’s involvement in the Sustainable Markets Initiative and the Terra Carta campaign, showing that indirect engagement via trade groups is the principal channel it uses. Beyond naming those associations, the airport does not identify which government bodies or individual policymakers it tries to influence, nor does it describe concrete actions such as letters, meetings or consultation submissions. The disclosure likewise stops short of naming any specific climate laws or regulations it has addressed; participation in the “Greek Compact of Sustainable Entrepreneurship” is referenced, but no particular legislation or rule changes are cited. Finally, the airport limits itself to broad aspirations—supporting “sustainable growth” and achieving net-zero carbon emissions by 2025—without detailing the legislative or regulatory outcomes it seeks to secure through its lobbying. Overall, the company offers only a general picture of climate-policy engagement, without the specificity needed to demonstrate full transparency on the policies, mechanisms and objectives involved.	1

Lobbying Governance

Overall Assessment	Comment	Score
None	Athens International Airport SA presents a comprehensive “corporate governance framework” and an embedded “enterprise risk management system” overseen by the Internal Audit department, Audit Committee, and Board of Directors, with “scheduled periodic audits” and a “Corporate Scorecard [that] measures performance against predefined targets on both financial and non-financial metrics.” However, we found no evidence of any processes or procedures specifically governing direct or indirect lobbying activities, no mention of any policy-alignment review or oversight structure for climate-related or other policy advocacy, and no disclosure of any individual or formal body responsible for overseeing lobbying or trade-association engagement.	0