Suzano SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited Suzano SA offers only limited visibility into its climate-related lobbying. It acknowledges that it seeks to influence policy—sending a delegation to COP26 to "engage the business sector and influence positive climate policies, such as carbon markets" and taking part in domestic discussions to secure "progress in defining the legal basis for regulating the carbon market in Brazil"—but it does not name any specific bill, regulation or government initiative it has actually lobbied. The company describes its methods in broad terms, citing "participation in more than 40 events related to different climate discussions," work through industry platforms such as Indústria Brasileira de Árvores (Ibá) and the Brazilian Coalition on Climate, Forestry and Agriculture, and wider "advocacy and engagement actions with stakeholders." However, it does not state whether these actions involved meetings, letters, public consultations or other concrete mechanisms, nor does it identify the governmental bodies or decision-makers that were approached. Likewise, the outcomes it pursues are framed generically—supporting carbon markets, fostering debate on carbon regulations, and aligning with a 1.5 °C pathway—without detailing the specific policy changes, targets or timelines it is advocating. Taken together, the disclosures reveal an intention to shape climate policy but lack the specificity needed to demonstrate a transparent, well-defined lobbying programme. 1
Lobbying Governance
Overall Assessment Comment Score
Strong Suzano has implemented a clear governance structure to guide both its direct and indirect climate-related policy engagement, backed by an explicit public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement. Internally, it create[s] a Working Group focused on Climate Engagement and Influence with meetings every two months, comprising executive members from Sustainability, Corporate Affairs, Legal, New Business, Carbon Business and Corporate Venture, and Communication, which monitors the voluntary and regulated carbon market, national and international events, methodology for emissions and removals, world climate trends and legal carbon mechanisms. Suzano has also been historically involved in the formulation of public policies and regulatory frameworks to ensure that the association's activities are in line with the objectives of the Paris Agreement and acts through associations (such as Global Compact, WBCSD Brazilian Chapter, Coalizo) to best strive and promote a healthy political-institutional environment, demonstrating some consideration its indirect lobbying alignment. Climate matters and the overarching strategy for engagement are supervised by the companys senior leadership through the Board of Directors and the Sustainability Committee, which is responsible for defining and monitoring the climate change management strategy, reflecting a formal oversight body. However, we found no evidence of a dedicated audit or third-party report evaluating the alignment of its lobbying activities, nor a detailed mechanism for reviewing or exiting association memberships whose positions may conflict with its climate goals. 3