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| Overall Assessment |
Analysis |
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None
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IRB-Brasil Resseguros SA’s disclosures focus on ESG policy oversight, with the Board of Directors providing “guidance for the application of this Policy and IRB’s ESG strategy” and the Executive Board “appointing and maintaining an Officer Responsible for compliance with this Policy”. The ESG Working Group “monitors the progress of the action plan approved internally for the implementation of this Policy” and proposes policy revisions. However, we found no evidence of any governance process specifically for lobbying activities or for aligning direct or indirect lobbying with the company’s climate or policy positions, as there is no mention of oversight structures, monitoring procedures, or accountability measures related to lobbying in the provided disclosures.
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E
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| Overall Assessment |
Analysis |
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Limited
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IRB-Brasil Resseguros gives only a brief view of its climate-policy lobbying. It identifies one specific initiative—the Brazilian Senate’s Bill 412/2022 on carbon-market regulation—and notes that a member of its Board of Directors took part in a public hearing of the Senate Environment Committee, but it does not describe any other legislation it has followed or confirm that this is the full extent of its engagement. The company discloses a single mechanism—attendance at that public hearing—and names the policymaking target, yet offers no detail on whether it also held bilateral meetings, submitted written comments, or engaged through trade associations. On substance, it signals broad support for establishing a Brazilian carbon market, stating that “The regulation of the carbon market could directly benefit indigenous, quilombola and riverside communities,” but sets out no concrete policy amendments, timelines, or quantitative goals it seeks to secure. Overall, the disclosure gives only a limited picture of what the company does, how it does it, and what specific outcomes it is pursuing.
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D
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