Aena SME SA

Aena provides only a brief indication that it tries to keep its policy advocacy consistent with its climate goals, noting that it "participates in several processes to ensure consistency of all activities with the climate change strategy of the company, both at a EU and national level" and that this includes "monitoring and participation in the processes of consultation of new legislation through the ACI (Airports Council International)" as well as the "elaboration of a position paper on Refuel EU". This shows the company recognises the need to align its direct and indirect lobbying with its climate strategy. However, the disclosure stops short of describing a structured governance process: no procedure is given for how lobbying positions are reviewed or approved, there is no reference to regular audits or criteria for assessing trade-association alignment, and no specific individual or committee is tasked with overseeing lobbying activities. The Sustainability and Climate Action Committee is described as responsible "to know, promote, guide and supervise the Company's objectives, action plans, practices and policies in environmental and social matters" and to "review... the Climate Action Plan", but these powers relate to operational sustainability rather than to lobbying or public-policy engagement. Because the evidence contains only a general commitment to consistency and lacks detail on oversight mechanisms, monitoring frequency, or accountability for lobbying alignment, this indicates limited governance rather than a well-defined process.