Cosan SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Cosan SA provides extensive and specific disclosure of its climate-policy lobbying. It identifies a wide range of measures on which it has intervened, including the RenovaBio carbon-pricing law, São Paulo State Government consultations on using natural gas and biomethane to decarbonise heavy transport, the ARSESP consultation to expand biomethane in piped gas, the Working Group “Corredores Sustentáveis” under the Ministry of the Economy, and ANEEL’s revision of Normative Resolution 482/2012 on distributed generation, as well as its participation in the São Paulo Environmental Agreement and contributions to Brazil’s Net Zero 2050 Climate Action Plan. The company also explains how it lobbies and whom it targets. It describes engaging “through public consultation, technical analysis, discussions about program rules” and lists the bodies approached, such as “the Regulatory Agency (ANP), the Ministries of Mines and Energy (MME), the Ministry of Agriculture, the National Congress,” the São Paulo State Government, ARSESP, ANEEL and the Ministry of the Economy, and notes that it acts both directly and “through representative entities such as UNICA, ABD and ABBI.” Cosan is equally clear about the outcomes it seeks. It states that it has “always proposed improvements to the [RenovaBio] program, so that it gains traction and has a growing and sustainable demand from CBios,” advocates replacing diesel with natural gas and biomethane in heavy transport corridors, supports incentives for distributed generation so that “energy from cleaner sources [can] have significant participation in the Brazilian energy matrix,” and aims to embed biomethane in piped gas networks and shape the Net Zero 2050 plan. By naming the specific policies, detailing the consultation, working-group and industry-association channels used, pinpointing the governmental addressees, and articulating the concrete changes it wants, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
None	The evidence focuses on the company’s “Políticas e no jeito Moove de ser e de conduzir nossos negócios” and the logging of its “Planejamento Estratégico EESG”, including the creation of an “ESG Work Group” and the use of a “materiality matrix” to define “flags” guiding its sustainability goals; however, we found no evidence of any processes, oversight structures, or accountability measures to govern the company’s direct or indirect lobbying activities in support of its climate change strategy, nor any disclosure of a named individual or formal body responsible for reviewing or aligning its policy-advocacy efforts.	0