Ferrovial SE – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Ferrovial discloses an overarching framework that covers lobbying within its wider Compliance Program, stating that this program includes a "Lobbying and Political Contributions Policy" and is "approved and supervised by the Board of Directors" with ongoing supervision "through the Audit and Control Committee, to whose Chairman reports the Chief Compliance and Risk Officer," who "reports periodically to the Committee, and at least once a year to the Board, on the effectiveness of the program." This indicates that a named individual and a board-level committee have explicit responsibility for oversight of lobbying activities. The company also confirms a climate-related commitment, answering "Yes" when asked whether it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," and notes that "Corporate Governance polices are implemented across the Company… as is the case of Trade Associations," suggesting that these policies are intended to guide external engagement. However, Ferrovial does not disclose any detailed procedure for reviewing or testing the alignment of either its direct advocacy or its membership in business associations against its climate strategy, beyond the general assertion that ethical principles apply; there is no evidence of periodic climate-lobbying audits, criteria for assessing trade-association positions, or actions taken when misalignment occurs. The available information therefore shows board-level oversight and a high-level Paris-alignment commitment but provides limited detail on the mechanisms used to monitor, manage, or correct climate-related lobbying, indicating moderate but not strong governance in this area. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Ferrovial discloses an overarching framework that covers lobbying within its wider Compliance Program, stating that this program includes a "Lobbying and Political Contributions Policy" and is "approved and supervised by the Board of Directors" with ongoing supervision "through the Audit and Control Committee, to whose Chairman reports the Chief Compliance and Risk Officer," who "reports periodically to the Committee, and at least once a year to the Board, on the effectiveness of the program." This indicates that a named individual and a board-level committee have explicit responsibility for oversight of lobbying activities. The company also confirms a climate-related commitment, answering "Yes" when asked whether it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," and notes that "Corporate Governance polices are implemented across the Company… as is the case of Trade Associations," suggesting that these policies are intended to guide external engagement. However, Ferrovial does not disclose any detailed procedure for reviewing or testing the alignment of either its direct advocacy or its membership in business associations against its climate strategy, beyond the general assertion that ethical principles apply; there is no evidence of periodic climate-lobbying audits, criteria for assessing trade-association positions, or actions taken when misalignment occurs. The available information therefore shows board-level oversight and a high-level Paris-alignment commitment but provides limited detail on the mechanisms used to monitor, manage, or correct climate-related lobbying, indicating moderate but not strong governance in this area.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Ferrovial provides a mixed but ultimately useful level of insight into its climate-policy lobbying. It names one concrete piece of legislation it helped shape – Spain’s 2014 “Energy Saving and Emission Reduction Plan in Buildings for energy rehabilitation of buildings in the residential and tertiary sector” – offering detail on how its advice fed into the measure. The company also describes more general engagement through its chairmanship of the Spanish Green Growth Group and through collaboration with international bodies, but no other individual bills or regulations are identified. On lobbying channels, Ferrovial explains that it (1) chairs the Spanish Green Growth Group and organises public conferences, (2) “provided solutions and advice to the Spanish Government” on energy-efficiency refurbishment and legal-framework changes, and (3) works within public-private project structures—clearly naming the Spanish Government as a principal target, although other audiences are not specified. The clearest disclosure concerns objectives: the company says it sought “significant energy consumption reductions and CO2 savings through urban renovation and building refitting,” called for amendments to “the legal framework regulating building refurbishment,” and promoted the creation of public-private partnerships to co-finance energy-efficiency investments, thereby setting out concrete policy outcomes it wants to see adopted. Overall, the company is moderately transparent: it reveals its main Spanish engagement mechanism and the outcomes it pursues, but lists only a single identifiable policy and gives limited detail about lobbying targets beyond Spain.	C