ACEA SpA

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.