Telefonica Brasil SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Telefônica Brasil demonstrates moderate governance of its climate-related lobbying activities through board-approved policies, internal training, and identified oversight, but it does not disclose a formal process for aligning its indirect lobbying via trade associations. The company notes that “Climate change (CC) objectives are part of the Environmental and Energy Policy which were approved by the Board of Executive Officers,” and highlights that its “Climate Action Plan, which were approved by the Board of Directors,” guide its sustainability priorities. It outlines that the “Institutional Relations area, which plays the closest role of dialogue with trade associations and governmental bodies,” received “dedicated training about Telefônica Brasil’s sustainability and CC initiatives,” and that this team is “led by the Institutional and Sustainability Vice President who oversees all governmental interactions” and “promotes regular meetings with all the staff in which are presented the company’s CO2 goals, climate change positions and objectives.” These elements establish clear processes and a named executive to ensure direct lobbying aligns with its climate commitments. However, the company does not disclose any mechanism to assess or align the positions of trade or industry associations it engages with, nor does it provide a formal review or audit of its climate lobbying alignment. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Telefônica Brasil demonstrates moderate governance of its climate-related lobbying activities through board-approved policies, internal training, and identified oversight, but it does not disclose a formal process for aligning its indirect lobbying via trade associations. The company notes that “Climate change (CC) objectives are part of the Environmental and Energy Policy which were approved by the Board of Executive Officers,” and highlights that its “Climate Action Plan, which were approved by the Board of Directors,” guide its sustainability priorities. It outlines that the “Institutional Relations area, which plays the closest role of dialogue with trade associations and governmental bodies,” received “dedicated training about Telefônica Brasil’s sustainability and CC initiatives,” and that this team is “led by the Institutional and Sustainability Vice President who oversees all governmental interactions” and “promotes regular meetings with all the staff in which are presented the company’s CO2 goals, climate change positions and objectives.” These elements establish clear processes and a named executive to ensure direct lobbying aligns with its climate commitments. However, the company does not disclose any mechanism to assess or align the positions of trade or industry associations it engages with, nor does it provide a formal review or audit of its climate lobbying alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Telefônica Brasil provides a solid level of transparency on its climate-related policy engagement. It specifies the exact legislative instruments it has worked on, including Decree 11.004/2022 governing the Telecommunications Universalization Fund (FUST) and complementary law PLP 77/2022, giving readers a clear picture of the measures under discussion. The company also identifies how and where it lobbies, noting direct engagement with the Ministry of Communications, the FUST Management Council, other Federal Executive bodies and the National Congress, which demonstrates both the mechanisms it uses and the policymaking targets it addresses. Finally, Telefônica Brasil is explicit about the outcomes it seeks: it wants FUST resources to be channelled into connectivity projects, to block any contingency of those funds through PLP 77/2022, and to expand the fund’s scope to cover mobile telephony and broadband in order to foster digital inclusion and support emissions-saving technologies. This level of detail on the policies, the engagement channels and the concrete objectives shows a strong commitment to transparent climate-policy lobbying.	3