Brembo NV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Brembo discloses a structured process for ensuring that its climate-related external engagement is aligned with its overall climate strategy, stating that “all activities regarding climate change mitigation and adaptation aspects are coordinated by the CSR Officer and specifically presented for approval to the CSR Steering Committee,” and that the Committee “defines guidelines for all business divisions and adopts Group policies … and ensures that climate change activities are consistent with Brembo Group strategy in all business divisions.” The company also confirms that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” indicating an explicit intention to align advocacy with climate goals. Oversight responsibility is clearly allocated: the CSR Steering Committee, “appointed by the Board,” reviews and approves these engagement activities, which signals board-level governance of alignment. However, the disclosure does not specify how lobbying positions are monitored in practice, gives no detail on reviewing trade-association memberships or on mechanisms for correcting or exiting misaligned lobbying, and provides no reference to audits or reporting of lobbying alignment. Overall, the presence of a governing body and a stated alignment process indicates moderate governance, but the absence of information on direct and indirect lobbying reviews or corrective actions limits the evidence of a more comprehensive framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Brembo discloses a structured process for ensuring that its climate-related external engagement is aligned with its overall climate strategy, stating that “all activities regarding climate change mitigation and adaptation aspects are coordinated by the CSR Officer and specifically presented for approval to the CSR Steering Committee,” and that the Committee “defines guidelines for all business divisions and adopts Group policies … and ensures that climate change activities are consistent with Brembo Group strategy in all business divisions.” The company also confirms that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” indicating an explicit intention to align advocacy with climate goals. Oversight responsibility is clearly allocated: the CSR Steering Committee, “appointed by the Board,” reviews and approves these engagement activities, which signals board-level governance of alignment. However, the disclosure does not specify how lobbying positions are monitored in practice, gives no detail on reviewing trade-association memberships or on mechanisms for correcting or exiting misaligned lobbying, and provides no reference to audits or reporting of lobbying alignment. Overall, the presence of a governing body and a stated alignment process indicates moderate governance, but the absence of information on direct and indirect lobbying reviews or corrective actions limits the evidence of a more comprehensive framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Brembo provides a solid level of transparency around what it is lobbying for in climate-related policy. It identifies several concrete policy files, including the EU “Euro 7” pollutant-emission standard for cars and vans, the EU “Fit for 55” legislative package, Italian “energy transition regulations for the automotive sector,” and measures to “incentivize the use of secondary materials” and promote a “circular economy.” The company explains that it engages policymakers by “participat[ing] in discussion tables with Italian policy makers, in particular with various government ministries or parliamentary committees,” clearly naming the forum it uses and the governmental targets of these discussions, although it does not describe any additional mechanisms such as written submissions or public consultations. Brembo is also explicit about the outcomes it is pursuing: it wants to “greatly reduce bureaucracy regarding the use of secondary raw materials” to spur circular-economy uptake, supports aligning automotive regulations with the Fit for 55 goal of “reducing net greenhouse-gas emissions by at least 55% by 2030,” and seeks to bring its braking products into line with Euro 7 to cut particulate emissions. By spelling out both its policy priorities and the specific changes it wants to see, the company demonstrates a strong—though not exhaustive—level of disclosure on its climate lobbying activity.	B