Klabin SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Klabin discloses a governance set-up that links climate-related external engagement to strategic oversight, noting that it has “restructured its team and created a specific corporate area of Sustainability and Environment that has as one of its objectives the day-to-day management of the issue with the responsibility of monitoring global and national climate agendas” and that this team “is responsible for operating and managing corporate issues related to the environment and sustainability.” Oversight is elevated to the Board through “a fixed sustainability committee made up of representatives of the organization’s board of directors whose objective is to discuss and insert sustainability-related issues (including climate change) into the organization’s strategic planning,” indicating a named body reviewing alignment. The company further states that “this ensures that the issues related to our direct and indirect activities are linked to our strategy of climate change and organizational sustainability,” and confirms that it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” These disclosures demonstrate both a formal policy/process for monitoring climate-related engagement and a clear oversight structure, suggesting moderate governance of lobbying alignment. However, the company does not disclose any systematic review of its direct lobbying positions, any assessment of trade association stances, or publication of a lobbying alignment report, so the detail regarding how lobbying activities are monitored, corrected, or escalated remains limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Klabin discloses a governance set-up that links climate-related external engagement to strategic oversight, noting that it has “restructured its team and created a specific corporate area of Sustainability and Environment that has as one of its objectives the day-to-day management of the issue with the responsibility of monitoring global and national climate agendas” and that this team “is responsible for operating and managing corporate issues related to the environment and sustainability.” Oversight is elevated to the Board through “a fixed sustainability committee made up of representatives of the organization’s board of directors whose objective is to discuss and insert sustainability-related issues (including climate change) into the organization’s strategic planning,” indicating a named body reviewing alignment. The company further states that “this ensures that the issues related to our direct and indirect activities are linked to our strategy of climate change and organizational sustainability,” and confirms that it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” These disclosures demonstrate both a formal policy/process for monitoring climate-related engagement and a clear oversight structure, suggesting moderate governance of lobbying alignment. However, the company does not disclose any systematic review of its direct lobbying positions, any assessment of trade association stances, or publication of a lobbying alignment report, so the detail regarding how lobbying activities are monitored, corrected, or escalated remains limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Klabin provides a basic but incomplete picture of its climate-policy lobbying. It names one specific measure it has worked on – “Decree No. 11,075, of May 19, 2022,” which sets up Brazil’s sectoral climate-mitigation plans and a national carbon market – and it also references more general engagement on an “international regulated carbon market,” yet it does not list any other concrete bills or regulations. The company explains several ways it seeks to influence policy, such as contributing suggestions through its industry association Ibá, taking part in Ibá work groups on the carbon agenda, submitting a document with recommendations to “responsible regulatory bodies,” and participating in multilateral forums like COP27, but it does not identify the specific government ministries, legislators or officials it targets. Klabin is clearer about its policy objectives: it openly supports the creation of a regulated carbon market in Brazil “without exceptions,” aligned with the Paris Agreement, and its submission advocates including carbon- and methane-credit systems and a national registry of transactions. Overall, the disclosure shows limited transparency—adequate detail on the desired outcome and some description of engagement channels, but only a single named policy and no precise identification of lobbying targets.	D