Enel SpA

Enel discloses a structured process that actively governs both its direct and indirect climate-related lobbying. The company states that "Enel is committed to ensuring that its direct and indirect advocacy activities are conducted in line with the objectives of the Paris Agreement," and that the "worldwide coordination of Enel's global public policy positioning on climate is ensured by the European Affairs unit," demonstrating an internal mechanism that steers direct engagement with policymakers. For trade-association activity, Enel reports that it "systematically verifies the consistency of the associations' positions with the climate policies shared at the Group level," detailing a two-stage review "before joining the association" and "after joining," followed by "a review of the level of alignment of the associations with Enel's strategy... conducted annually," which shows ongoing monitoring and the ability to act on misalignment. Oversight is anchored at board level: "Il Comitato per la Corporate Governance e la Sostenibilità ha il compito di verificare periodicamente la corretta applicazione della presente Engagement Policy," indicating that a Board committee periodically checks the policy's application and proposes adjustments to the Board of Directors. Together, these disclosures indicate strong governance of both direct and indirect lobbying activities; however, Enel does not disclose a stand-alone, publicly available lobbying alignment report or an externally assured audit of its lobbying positions, so transparency regarding the outcomes of its annual reviews remains limited.