Sociedad Matriz SAAM SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Sociedad Matriz SAAM SA has implemented a general framework to govern its lobbying activities through a “Policy on Relations with Public Officials and Politically Exposed Persons” that is “part of the SM SAAM Compliance Program, Crime Prevention Model and Code of Ethics” and “regulates the Company’s lobbying activities.” This policy applies across all subsidiaries and “outlines minimum requirements for desirable practices when interacting with public officials,” and the company notes that “any bill, congressional decision, policy, plan or program related to limiting global warming to 2°C, promoting renewable energies, or supporting carbon pricing … is regulated by the aforementioned Policy.” While these disclosures establish a clear policy foundation, the company does not disclose a process for monitoring or reviewing climate lobbying alignment, nor does it identify a designated individual or formal body overseeing lobbying governance, and it provides no details on how it ensures that its direct and indirect lobbying consistently aligns with its climate-related objectives. View Sources	1

Overall Assessment

Analysis

Score

Limited

Sociedad Matriz SAAM SA has implemented a general framework to govern its lobbying activities through a “Policy on Relations with Public Officials and Politically Exposed Persons” that is “part of the SM SAAM Compliance Program, Crime Prevention Model and Code of Ethics” and “regulates the Company’s lobbying activities.” This policy applies across all subsidiaries and “outlines minimum requirements for desirable practices when interacting with public officials,” and the company notes that “any bill, congressional decision, policy, plan or program related to limiting global warming to 2°C, promoting renewable energies, or supporting carbon pricing … is regulated by the aforementioned Policy.” While these disclosures establish a clear policy foundation, the company does not disclose a process for monitoring or reviewing climate lobbying alignment, nor does it identify a designated individual or formal body overseeing lobbying governance, and it provides no details on how it ensures that its direct and indirect lobbying consistently aligns with its climate-related objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Sociedad Matriz SAAM SA is highly transparent about its position on climate-related lobbying. The company unequivocally states that it undertakes no lobbying at all, noting that “Lobbying, interest representation or similar groups US$ 0 … for the years 2020 to 2023” and that “SM SAAM does not fund activities classified as political nor contribute money or goods to parties, candidates for public office, or their representatives in any of the countries where it operates.” It also references its “Policy on Relations with Public Officials and Politically Exposed Persons,” which aligns with Chile’s Lobby Law (Law No. 20,730), demonstrating a formal internal framework that prohibits such activities. By providing specific zero-spend figures, detailing the legal framework it follows, and explicitly confirming it seeks no policy changes or outcomes through lobbying, the company offers full clarity on all three dimensions of disclosure—policies, mechanisms, and outcomes—resulting in a comprehensive level of transparency.	4