Atresmedia Corp de Medios de Comunicacion SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Atresmedia provides limited but explicit disclosure that its external engagement should align with its climate objectives, stating that it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement” and outlining a process whereby “Atresmedia has put the following processes in place” to ensure consistency, including oversight from “a Corporate Responsibility (CSR) Committee that ensures the success of the policy objectives and the integration of sustainability within all the strategic lines and that monitor the implementation of the climate change strategy.” This indicates that at least one internal body is charged with reviewing how engagement activities relate to climate strategy, which suggests some governance of policy engagement. However, the disclosure focuses on broad environmental management and employee awareness rather than describing how lobbying activities—whether direct advocacy or participation in trade associations—are tracked, evaluated for alignment, or corrected. There is no description of any review of industry-association positions, no mention of procedures for monitoring or approving lobbying communications, and no identification of a specific individual responsible for lobbying oversight. Consequently, while the commitment to Paris-aligned engagement and the existence of a committee provide evidence of rudimentary governance, the company does not disclose a detailed process for managing or auditing climate-related lobbying activities, nor does it address indirect lobbying through external associations. View Sources	D

Overall Assessment

Analysis

Score

Limited

Atresmedia provides limited but explicit disclosure that its external engagement should align with its climate objectives, stating that it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement” and outlining a process whereby “Atresmedia has put the following processes in place” to ensure consistency, including oversight from “a Corporate Responsibility (CSR) Committee that ensures the success of the policy objectives and the integration of sustainability within all the strategic lines and that monitor the implementation of the climate change strategy.” This indicates that at least one internal body is charged with reviewing how engagement activities relate to climate strategy, which suggests some governance of policy engagement. However, the disclosure focuses on broad environmental management and employee awareness rather than describing how lobbying activities—whether direct advocacy or participation in trade associations—are tracked, evaluated for alignment, or corrected. There is no description of any review of industry-association positions, no mention of procedures for monitoring or approving lobbying communications, and no identification of a specific individual responsible for lobbying oversight. Consequently, while the commitment to Paris-aligned engagement and the existence of a committee provide evidence of rudimentary governance, the company does not disclose a detailed process for managing or auditing climate-related lobbying activities, nor does it address indirect lobbying through external associations.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Atresmedia provides a moderate level of transparency around its climate-policy lobbying. It clearly identifies the policy it has worked on, naming the “Draft Royal Decree regulating the content of reports on the estimated financial impact of climate change risks implementing article 32.5 of Law 7/2021, of 20 May, on climate change and energy transition issued by the Spanish Government,” but this is the only measure disclosed. The company is more detailed about how it engages: it “participated in the sustainability working group of the Association of Spanish Securities Issuers,” can “submit comments and contributions to legislators,” and maintains a “relationship of dialogue and cooperation with the Public Administrations and especially with the National Securities Market Commission (CNMV),” thereby revealing several concrete mechanisms and the specific targets of those efforts. However, it stops short of spelling out the precise policy changes it wants to see, merely stating that it seeks to “have a certain influence on the definition and application of climate-related laws, regulations and reporting frameworks.”	C