Acerinox SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Acerinox SA provides a basic but limited picture of its climate-policy lobbying. It identifies one concrete policy engagement, stating that its European subsidiary was involved in the update of the Ferrous Metal Processing BREF under the “IPPC Directive,” which will guide future emission-limit values for hot- and cold-rolling steel activities. The company also discloses one clear lobbying mechanism and target, noting that “Acerinox Europa was one of the members of the Technical Working Group within the EIPPCB,” where it shared “data and BATs knowledge” directly with the European IPPC Bureau during the revision process. Finally, it explains the single outcome it is pursuing—to influence the setting of “future ELVs (Emission Limit Values)” for the sector— and affirms its support for the policy and alignment with the Paris Agreement. While these details demonstrate some openness, the disclosure is confined to a single policy, a single engagement channel, and one stated objective, leaving most of the company’s broader climate-lobbying activity unaddressed.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Acerinox SA discloses that its Chief Sustainability Officer is responsible for supervising and coordinating engagement activities to ensure alignment with the company's climate-related commitments established in its Sustainability Plan 2021-2025, which targets carbon neutrality by 2050. While this indicates some level of oversight, the evidence does not provide details on specific processes or mechanisms for monitoring or managing lobbying activities, nor does it address alignment of indirect lobbying through trade associations or industry bodies. Additionally, there is no mention of a recurring review process or publicly available lobbying audit/report. The company's commitment to aligning engagement activities with the Paris Agreement goals is noted, but the governance framework for lobbying is not clearly defined or detailed in the evidence provided.	1