Eni SpA

Eni has implemented a multi-step governance process to align its indirect lobbying via business associations with its climate-related strategy, but the company does not disclose a corresponding framework for its direct policy engagement. It has a "policy on the Eni's responsible engagement on climate change within business associations" under which "every 2 years we conduct an assessment to check the alignment between the business association positions and the Eni's principles on climate-related topics," and it applies a clear methodology that classifies positions as "partially aligned" or "not aligned" based on publicly available data. This process, "coordinated by the Climate Change Strategy and Positioning Dpt. at corporate level" with input from the Legal Department and Office of the CEO, includes defined actions: the company "will endeavour to bring our view in the association and, if the contrast remains, we will seriously consider withdrawing from the association." Assessment results are "presented to our board and will be publicly disclosed," demonstrating board-level oversight, and the Executive Vice President of the HSEQ Department alongside the Sustainability and Scenarios Committee provide formal governance. However, while the framework for indirect lobbying through associations is detailed, we found no evidence of a parallel system to monitor or manage direct engagement with policymakers.