Snam SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Snam gives an unusually full picture of its climate-policy lobbying. It names a wide array of concrete legislative files it works on – among them the EU “Gas and Hydrogen Decarbonization Package,” “Fit for 55” elements such as RED III, EU ETS and CBAM, the “Net Zero Industry Act,” the EU Methane-emissions Regulation, and national measures including decrees that support biomethane and hydrogen production and updates to the Italian Integrated National Energy and Climate Plan. It also lists project-specific procedures before the Italian energy regulator Arera (e.g., the LNG Piombino delivery procedure and the Adriatic Project) and points to its advocacy for the SoutH2 Corridor and the Callisto Mediterranean CO₂ Network being placed on the EU Projects of Common Interest list. The company is equally specific about how and where it lobbies. It discloses participation in at least “10 EU public consultations,” a “cycle of hearings of the European Parliament,” “>150 meetings with National and Local Institutions in 2023,” and the submission of signed letters of support from ministries in Italy, Austria and Germany. It identifies targets such as the Italian authority Arera, the Italian Government’s hydrogen-strategy team, European Commission directorates, and national energy and environment ministries, and confirms its registration in the EU Transparency Register. These details show the direct, indirect and coalition-based mechanisms it uses, and who receives its advocacy. Finally, Snam states clear policy outcomes it is seeking. It supports strengthening EU carbon-pricing instruments, creating a Social Climate Fund, adding hydrogen to CBAM, establishing “ambitious targets and efficient subsidy schemes” for hydrogen and biomethane, and a harmonised EU framework for CO₂ transport and storage. Project-level goals are likewise precise, such as enabling the SoutH2 Corridor to deliver 40 % of REPowerEU’s hydrogen-import target and achieving 500 Mt of CO₂ storage capacity in the Callisto network. By combining detailed policy lists, well-defined lobbying channels and explicit desired results, Snam demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Snam SpA demonstrates a comprehensive climate lobbying governance process that integrates transparency, accountability, and alignment with its climate-related goals. The company has introduced a Climate Lobbying Policy in 2023, which outlines "the principles underlying the Group's climate strategy, advocacy position and affiliations with associations: the six Key Climate Advocacy Drivers." This policy is supported by robust oversight mechanisms, including the Board of Directors, which "plays a central role in overseeing the climate change strategy" and periodically reviews and approves climate-related targets, strategic plans, and monitoring indicators. The Board is supported by three internal committees, including the Environmental, Social & Governance and Energy Transition Scenarios Committee, which examines "long-term energy transition scenarios underpinning the Strategic Plan" and monitors the decarbonization roadmap. Furthermore, Snam has established processes to ensure alignment of external engagement activities with its climate commitments, such as "an annual monitoring activity carried out by the competent functions along with the Institutional Affairs function to guarantee the alignment of the associations memberships with the business objectives, including those related to the climate change commitment." The company also discloses its climate-related lobbying activities and assesses their alignment with the Paris Agreement objectives, demonstrating "clear commitment to climate goals." Additionally, Snam has implemented internal procedures for managing relations with associations, including evaluations to assess alignment with climate goals and sustainable principles, and has committed to "expose our point of view and our disagreement and, in case, we consider to exit from the Association" in cases of misalignment. This indicates a robust governance framework that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms, accountability structures, and public transparency in place.	4