Rumo SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Rumo discloses a limited process for ensuring that its public-policy engagement aligns with its climate objectives, noting that it "describe[s] the process… to ensure that your engagement activities are consistent with your overall climate change strategy" and that a "multidisciplinary group formed by areas such as Sustainability, Energy Efficiency and Operations… meets every two weeks and is responsible for conducting the company's strategy in relation to climate change." The company also states that it "has a public commitment… to conduct [its] engagement activities in line with the goals of the Paris Agreement" and participates in the "CEBDS Climate Change Working Group, which is responsible for issuing public position statements [and] public policies." These disclosures indicate an intention to align external advocacy with climate strategy and show at least one internal forum that reviews such engagement. However, the evidence does not disclose any formal governance mechanism that explicitly oversees lobbying activities, no description of how direct or indirect lobbying is monitored or audited, no references to assessing trade-association positions, and no identification of a specific board committee or executive who signs off on lobbying alignment. Consequently, while there is some acknowledgement of climate-aligned engagement, the overall lobbying-governance framework remains largely undeveloped and lacks transparency on oversight, monitoring procedures and accountability for lobbying alignment. View Sources	D

Overall Assessment

Analysis

Score

Limited

Rumo discloses a limited process for ensuring that its public-policy engagement aligns with its climate objectives, noting that it "describe[s] the process… to ensure that your engagement activities are consistent with your overall climate change strategy" and that a "multidisciplinary group formed by areas such as Sustainability, Energy Efficiency and Operations… meets every two weeks and is responsible for conducting the company's strategy in relation to climate change." The company also states that it "has a public commitment… to conduct [its] engagement activities in line with the goals of the Paris Agreement" and participates in the "CEBDS Climate Change Working Group, which is responsible for issuing public position statements [and] public policies." These disclosures indicate an intention to align external advocacy with climate strategy and show at least one internal forum that reviews such engagement. However, the evidence does not disclose any formal governance mechanism that explicitly oversees lobbying activities, no description of how direct or indirect lobbying is monitored or audited, no references to assessing trade-association positions, and no identification of a specific board committee or executive who signs off on lobbying alignment. Consequently, while there is some acknowledgement of climate-aligned engagement, the overall lobbying-governance framework remains largely undeveloped and lacks transparency on oversight, monitoring procedures and accountability for lobbying alignment.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Rumo SA provides only limited insight into its climate-policy lobbying. It indicates that it works on “Climate Neutrality” and the creation of a “Mandatory Carbon Market” in Brazil, but these references remain broad and do not clearly identify particular bills or regulatory proposals. The company does explain the channels it uses, noting its “active participation in the Brazilian Business Council for Sustainable Development (CEBDS) and the Climate Chamber” and its membership in “Coalizão Brasil Clima, Florestas e Agricultura,” yet it does not specify which governmental bodies or officials these forums seek to influence. Finally, the desired outcomes are articulated only in general terms—promoting “the transition to a low-carbon economy” and positioning Brazil as a leader in a “new low-carbon, competitive, responsible and inclusive economy”—without detailing concrete policy changes it wants to see enacted. As a result, the disclosures offer a basic outline of involvement but fall short of full transparency on the specific policies, lobbying methods, and legislative outcomes the company pursues.	D