SOL SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	SOL SpA discloses a basic internal mechanism to keep its policy-related engagement aligned with its climate objectives, stating that "The participants in these engagement activities are usually Directors or their direct employees" and that those Directors sit on the "Safety, Health, Environment and Quality Committee, that was set up with the mandate of approving sustainability objectives as well as coordinating and stimulating the operational structures of all Group companies on the topic." By noting that "This process ensures that our engagement activities are consistent with our overall climate change strategy," the company indicates an explicit process for reviewing advocacy against climate goals and names a formal body responsible for oversight, which suggests a moderate level of governance. However, the disclosure provides no detail on how the committee monitors or evaluates the content of direct lobbying, gives no information on the company’s approach to indirect lobbying through trade associations, and omits any reference to conducting or publishing alignment reviews or audits; indeed, the company confirms "No, and we do not plan to have one in the next two years" when asked about a public commitment to align engagement with the Paris Agreement. Therefore, while an oversight structure is identified, the absence of publicly described monitoring criteria, trade-association review, or external reporting indicates that the governance framework remains limited in scope and transparency. View Sources	C

Overall Assessment

Analysis

Score

Moderate

SOL SpA discloses a basic internal mechanism to keep its policy-related engagement aligned with its climate objectives, stating that "The participants in these engagement activities are usually Directors or their direct employees" and that those Directors sit on the "Safety, Health, Environment and Quality Committee, that was set up with the mandate of approving sustainability objectives as well as coordinating and stimulating the operational structures of all Group companies on the topic." By noting that "This process ensures that our engagement activities are consistent with our overall climate change strategy," the company indicates an explicit process for reviewing advocacy against climate goals and names a formal body responsible for oversight, which suggests a moderate level of governance. However, the disclosure provides no detail on how the committee monitors or evaluates the content of direct lobbying, gives no information on the company’s approach to indirect lobbying through trade associations, and omits any reference to conducting or publishing alignment reviews or audits; indeed, the company confirms "No, and we do not plan to have one in the next two years" when asked about a public commitment to align engagement with the Paris Agreement. Therefore, while an oversight structure is identified, the absence of publicly described monitoring criteria, trade-association review, or external reporting indicates that the governance framework remains limited in scope and transparency.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	SOL SpA provides only limited insight into its climate-related lobbying. It indicates that it participates in “main working groups and events” and holds a seat on the “Board of Directors of the Association H2IT,” showing that it employs indirect mechanisms such as industry-association involvement and multi-stakeholder forums, yet it does not identify which ministries, regulators or individual decision-makers it seeks to influence. The company signals an interest in hydrogen-related policy, stating that it is “offering the necessary support for the definition of a clear regulatory framework” and focused on “raising awareness of the importance of hydrogen in a zero-emission energy system,” but it stops short of naming any concrete law, regulation, or legislative proposal. Likewise, its desired outcomes are framed in broad terms—promoting the development of hydrogen infrastructure and a clearer regulatory environment—without disclosing specific amendments, targets, timelines, or quantitative goals. Because the disclosures remain high-level and omit the detailed policies, lobbying targets, and measurable outcomes sought, the overall transparency of SOL SpA’s climate-policy lobbying is limited.	D