Vibra Energia SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Vibra Energia provides an unusually detailed picture of its climate-policy lobbying. It lists several identifiable pieces of legislation and initiatives it has worked on, including “Bill 412/22” to regulate the Brazilian Emissions Market, “Bill 1873/21” creating the National Program for Advanced Renewable Fuels, “Bill 528/21” establishing a mandatory emissions-compensation scheme, the federal “Combustível do Futuro” programme, ANP’s “Public Consultation 11/2022” on biofuels, and the ongoing RenovaBio framework. The company also explains exactly how it seeks to influence these measures: it “takes technical data to meetings with policymakers,” “directly participates in debates and public consultations,” “encourages the participation of trade associations,” and “responds to consultations,” targeting the Chamber of Deputies, the parliamentary rapporteurs of the above bills and relevant Federal Government officials. Finally, Vibra is explicit about what it wants those engagements to deliver—for example, it says it “works to create the Brazilian Emission Reduction Market (MBRE) that is compatible with established international markets,” aims to “encourage research on advanced biofuels and promote their production and consumption,” and wants the Fuel of the Future programme to ensure “the carbon footprint is considered in the complete cycle, from cradle to grave.” By naming the policies, the channels used and the concrete policy changes it seeks, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Vibra Energia SA has implemented a structured process to align its public policy engagement with its climate strategy, stating that "Vibra systematically monitors and analyzes the opportunities for public policies that may impact its activity and proposes them" and that "The institutional relationship area is responsible for leading public policy opportunities, including proposals for new legislation and directing such opportunities to areas of the company that have some type of involvement with the subject in question." The company explains that "One of the areas consulted in this process is the ESG, which coordinates the company's climate change strategy," ensuring that "our internal processes that directly or indirectly influence public policies are aligned with Vibra's climate change strategy." While these disclosures establish a clear mechanism for evaluating and embedding climate considerations into both direct and indirect lobbying channels, we found no evidence of a named individual or formal body, such as a board committee or executive role, tasked with overseeing or reviewing the alignment of its lobbying activities.	2