Raizen SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Raízen provides a very full picture of its climate-policy lobbying. The company explicitly names a wide range of specific measures it has worked on, including Brazil’s National Biofuels Policy “RenovaBio,” Draft Bill 528/2021 and Decree 11,075/2022 to create the national carbon-market (SINARE), the Energy Efficiency Program of ANEEL, California “air pollution legislation” overseen by the California Air Resources Board, the EU Renewable Energy Directive (RED II), the Sustainable Aviation Fuel (SAF) mandate, the Carbon Border Adjustment Mechanism, the proposed EU Deforestation Act, and the São Paulo Environmental Agreement. It also describes how it engages: maintaining “constant interaction with public policy makers at the state and federal levels,” holding discussions with ANEEL, “directly engaging with stakeholders from the Legislative branches” and “liaising with stakeholders from the Executive branch,” working through trade associations such as UNICA, ABBI and CNI, joining international advocacy coalitions, taking part in public consultations and providing technical studies, and undertaking targeted outreach to the California Air Resources Board and Members of the European Parliament. Finally, Raízen is clear about the concrete outcomes it seeks. It wants a “regulated market” for carbon credits in Brazil that is aligned with international standards and can impose “sanctions to trade partners that are non-compliant,” advocates for “greater fungibility” between regulated and voluntary carbon markets, proposes improvements to RenovaBio to sustain demand for CBIOs, seeks to have sugarcane ethanol recognised by CARB as “one of the best carbon footprints among current first-generation biofuel technologies,” and presses the EU to “include a pathway for crop-based biofuels” in the SAF mandate and allow biofuels to “continue to play a relevant role in Europe’s path to a low-carbon energy matrix.” By naming the policies, detailing the forums and targets of engagement, and articulating the precise changes it wants, the company demonstrates a high degree of transparency across all dimensions of its climate lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Raízen SA outlines a clear structure for aligning its advocacy with its climate-change strategy, stating it has “a dedicated team responsible for engaging with policy makers in Brazil (in all three Branches) and an advocacy expert in the Sustainability Team dedicated to monitor and engage with national and international stakeholders” that “allows the company to closely monitor the proposal, discussion and implementation processes of public policies related to climate change and sustainability issues.” It also affirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” signaling its intent to align direct lobbying with international climate goals. However, the company does not disclose a named individual or formal committee charged with oversight of these lobbying activities, nor does it provide a detailed process for reviewing or aligning indirect lobbying through trade associations or industry bodies, such as criteria for engagement, regular audits, or exit mechanisms. We found no evidence of a recurring review cycle, formal sign-off steps, or a publicly available report detailing how its advocacy positions are assessed against its climate-change commitments.	2