Engie Brasil Energia SA

Engie Brasil Energia SA has implemented a structured process to evaluate and align its indirect lobbying through industry associations with its climate goals, notably carrying out a 2021 review that "performed a detailed assessment of the alignment of these associations with the objectives of the Paris Agreement" and committing that "the assessment of the alignment of associations will be carried out annually and an updated version will be available every two years on the ENGIE Group's corporate website." The company further commits to "supporting climate action aligned with the Paris Agreement when engaging with policymakers" and to "monitoring and disclosing climate policy alignment for their companies and their major industry/trade associations," demonstrating intent to govern both direct and indirect engagement. However, while the "Policy is endorsed by the Board of Directors" and overseen "through reports from its Sustainability Committee," there is no clear description of a formal process or accountable individual or committee specifically dedicated to reviewing and managing the company's direct lobbying activities or its policy engagement plans. We found no evidence of defined criteria for evaluating direct lobbying positions or a named function responsible for ongoing oversight of policy advocacy alignment with climate objectives, indicating that governance of direct climate lobbying lacks the same level of procedural detail as the indirect association-review mechanism.