Italgas SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Italgas provides extensive and specific disclosure about its climate-policy lobbying. It names multiple EU files it has worked on, including the “Proposal for a legislative act on methane leakage in the energy sector,” the companion “Regulation on methane emissions reduction in the energy sector and amending Regulation (EU) 2019/942,” the “Revision of the Energy Performance of Buildings Directive 2010/31/EU,” the “Hydrogen and decarbonised gas market package” that reviews Gas Directive 2009/73/EC and Regulation 715/2009, and other measures such as TEN-E and RED II, showing clear identification of the legislation it seeks to influence. The company also describes how it lobbies: it “presented position papers and held discussions with Members of the European Parliament (MEPs) and National representatives in the Council,” engaged in “direct contacts with DG ENERGY officers,” took part in a webinar hosted by the Directorate-General ENERGY, uploaded feedback on the Commission’s “Have Your Say” portal, and used industry platforms such as GD4S and Eurogas, thereby detailing several distinct mechanisms and naming the precise EU bodies it targets. Finally, Italgas sets out the concrete outcomes it pursues, advocating for “the recognition of a specific gas DSOs role in the nascent hydrogen market,” “differentiated unbundling rules” for DSOs, the creation of “a specific gas DSO Entity… to contribute to the revision of market codes,” and technical amendments to the methane-leakage proposal, such as aligning monitoring with UNEP’s OGMP 2.0 and adjusting repair frequencies. By coupling clearly identified policy dossiers with explicit lobbying channels and well-defined policy changes it seeks, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Italgas discloses a structured process to govern its indirect lobbying through trade associations by applying a “dual approach” under which “each new membership proposal is examined to assess (1) its consistency with Italgas’ strategic objectives, including those related to climate change … (4) the economic and human resources effort” and by ensuring that “the planning documents and position papers drafted by the associations are analyzed and if necessary … amended … to ensure consistency with Italgas’ strategic positions and views to fight climate change.” Oversight of this work is provided by the Sustainable Value Creation Committee, which “examines any sustainability initiative in agreements submitted to the BoD, also as to the subject of climate change … and the gas advocacy of the Group,” and the Board of Directors is periodically informed of these reviews. The company also publicly commits that “We carry out engagement initiatives and pursue our sustainability objectives in line with the commitments set out in the Paris Agreement.” However, Italgas does not disclose any equivalent alignment process or oversight for its direct lobbying activities, nor does it name a specific individual responsible for reviewing lobbying alignment or describe board sign-off of climate-related lobbying plans.	2