ACEA SpA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate ACEA SpA provides a moderate level of transparency about its climate-policy lobbying. It identifies two specific regulatory processes it has engaged on – Article 77 of the Integrated Text on Electrical Quality, which obliges distributors to submit resilience plans to the Italian regulator ARERA, and the implementation of the EU Emissions Trading System through EU Directive 2003/87 and Italy’s Legislative Decree 47/2020 – giving readers a clear sense of the concrete policies under discussion. The company also names the public-sector bodies it approaches, stating that it works with ARERA on electricity-grid resilience and with the National Committee responsible for administering the EU ETS, thereby revealing both the channels and the targets of its advocacy. In terms of desired outcomes, ACEA explains that it wants to help “define the Risk Index for substations of the electricity grid” and to prepare the resilience plan required by Article 77, but it is silent on what changes, if any, it seeks within the EU ETS, leaving many of its policy objectives unspecified. Overall, while the company gives useful detail on two engagements, the limited number of policies covered and the lack of explicit goals for some of its lobbying mean the disclosure is informative but not yet comprehensive. 2
Lobbying Governance
Overall Assessment Comment Score
Limited Acea SpA discloses a broad commitment to ensure that its external engagement is aligned with its climate objectives, noting that "Acea has a conduct in line with the Paris agreement" and confirming that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement". This indicates that the company has at least acknowledged the need for alignment between its advocacy and climate strategy. However, the evidence provided focuses primarily on the company’s overall ESG governance—detailing the roles of the Board of Directors, the Ethics and Sustainability Committee and the Risk & Compliance department—without specifying how these bodies oversee or review lobbying or policy-advocacy activities. There is no description of processes for monitoring direct lobbying, managing positions taken through trade associations, conducting alignment reviews, or assigning explicit responsibility for lobbying oversight. As such, while the commitment to Paris-aligned engagement suggests the beginnings of a governance approach, the company does not disclose the mechanisms, monitoring procedures, or accountable parties that would demonstrate a more robust lobbying-governance framework. 1