ACS Actividades de Construccion y Servicios SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	ACS outlines a moderate but still developing framework for governing its climate-related lobbying, centred on a Board-approved “Industry Association Engagement and Tracking Policy” that “sets out the procedure to be followed by ACS and its Group in selecting and participating in these associations” and obliges management to “assess whether the associations it participates in are aligned with the Group's policies and principles.” Oversight is explicitly assigned: “the Board approved… the General Compliance Policy… and, through the Audit Committee and the Compliance Committee, it has taken charge of regularly assessing its effectiveness,” while “the ACS Group's Audit Committee is responsible for monitoring aspects related to climate change.” The company further states that its external engagement will be consistent with its climate ambitions, noting “ACS Group has a clear commitment to support the Paris Agreement” and confirming it has “a public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement.” These elements show a disclosed policy, a monitoring process and named supervisory bodies, indicating solid governance of indirect lobbying. Nonetheless, the disclosures do not explain how direct lobbying by ACS employees is reviewed or approved, offer no detail on the criteria or results of association alignment checks, and there is no standalone climate-lobbying audit or report; thus key aspects of comprehensive transparency and full coverage remain undisclosed. View Sources	C

Overall Assessment

Analysis

Score

Moderate

ACS outlines a moderate but still developing framework for governing its climate-related lobbying, centred on a Board-approved “Industry Association Engagement and Tracking Policy” that “sets out the procedure to be followed by ACS and its Group in selecting and participating in these associations” and obliges management to “assess whether the associations it participates in are aligned with the Group's policies and principles.” Oversight is explicitly assigned: “the Board approved… the General Compliance Policy… and, through the Audit Committee and the Compliance Committee, it has taken charge of regularly assessing its effectiveness,” while “the ACS Group's Audit Committee is responsible for monitoring aspects related to climate change.” The company further states that its external engagement will be consistent with its climate ambitions, noting “ACS Group has a clear commitment to support the Paris Agreement” and confirming it has “a public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement.” These elements show a disclosed policy, a monitoring process and named supervisory bodies, indicating solid governance of indirect lobbying. Nonetheless, the disclosures do not explain how direct lobbying by ACS employees is reviewed or approved, offer no detail on the criteria or results of association alignment checks, and there is no standalone climate-lobbying audit or report; thus key aspects of comprehensive transparency and full coverage remain undisclosed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	ACS Group offers only limited insight into its climate-related lobbying. The disclosure notes that the company takes part in forums such as the Spanish Chamber of Commerce and the MIT Climate and Sustainability Consortium, indicating an indirect mechanism of engagement, but it does not identify the policymakers or jurisdictions it seeks to influence, nor does it describe specific activities such as meetings, submissions, or letters. The company does not name any climate laws, regulations, or policy proposals it has lobbied, and it provides no explanation of the policy positions or outcomes it aims to achieve. As a result, readers learn little more than the fact that the company belongs to certain associations, with no clarity on which climate issues are addressed, how influence is exerted, or what policy changes the company supports or opposes.	D