El.En. SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	El.En. SpA relies on its internal sustainability governance framework to coordinate external engagement with climate commitments but does not disclose any specific governance process for its lobbying activities. It explains that “the relationship and dialogue with communities and institutions is managed internally at the Group level and at single subsidiary level,” and that in 2018 the Board of Directors asked its Control and Risk Committee (renamed in 2021 the “Control and Risk, Related Party Transactions and Sustainability Committee”) to review “the company’s sustainability policies and goals and the supervision of the related Plan.” The company further details that an Executive Director in charge of internal control defined its “strategic sustainability guidelines, the Sustainability Plan and the review of the Consolidated NonFinancial Statement,” while a “Global Sustainability Manager” proposes the Group-wide strategy and “submitted the Plan to the Control, Risk and Sustainability Committee,” after which the Plan “was then proposed and approved by El.En.’s Board of Directors and disclosed to all subsidiaries.” Despite this oversight of sustainability, we found no evidence of processes or named individuals responsible for monitoring or managing direct or indirect lobbying, nor any criteria for ensuring lobbying alignment with its climate positions. The company also confirms it does not yet have a public commitment to conduct engagement in line with the goals of the Paris Agreement, acknowledging “No, but we plan to have one in the next two years.” View Sources	0

Overall Assessment

Analysis

Score

None

El.En. SpA relies on its internal sustainability governance framework to coordinate external engagement with climate commitments but does not disclose any specific governance process for its lobbying activities. It explains that “the relationship and dialogue with communities and institutions is managed internally at the Group level and at single subsidiary level,” and that in 2018 the Board of Directors asked its Control and Risk Committee (renamed in 2021 the “Control and Risk, Related Party Transactions and Sustainability Committee”) to review “the company’s sustainability policies and goals and the supervision of the related Plan.” The company further details that an Executive Director in charge of internal control defined its “strategic sustainability guidelines, the Sustainability Plan and the review of the Consolidated NonFinancial Statement,” while a “Global Sustainability Manager” proposes the Group-wide strategy and “submitted the Plan to the Control, Risk and Sustainability Committee,” after which the Plan “was then proposed and approved by El.En.’s Board of Directors and disclosed to all subsidiaries.” Despite this oversight of sustainability, we found no evidence of processes or named individuals responsible for monitoring or managing direct or indirect lobbying, nor any criteria for ensuring lobbying alignment with its climate positions. The company also confirms it does not yet have a public commitment to conduct engagement in line with the goals of the Paris Agreement, acknowledging “No, but we plan to have one in the next two years.”

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	El.En. SpA demonstrates a strong level of transparency around its climate lobbying activities. The company clearly names the specific policy frameworks it engages on, including the “European Green Deal,” the “Paris Agreement,” and “EU Regulation 852/2020 – Taxonomy Regulation,” and also discloses its work on the creation of energy communities for renewable energy production. In terms of its engagement approach, it explains that “several El.En. group companies meet directly policy makers within projects involving other local companies,” establishing “working tables” to plan concrete actions and that it “actively participates in the meetings organized by the Municipality as a leader company towards change and energetics transition,” illustrating its mechanisms of direct meetings and multi-stakeholder tables. The company specifies the outcomes it seeks—efforts to “reduce emissions,” “improve the private and public mobility system with a view to sustainability,” “identify solutions to give new life to waste through actions of reuse and recycling,” and “promote shared projects for the production and use of renewable energy”—and confirms its full support for these initiatives in line with the Paris Agreement. Overall, El.En. SpA provides detailed disclosure of the policies, mechanisms, and outcomes that underpin its climate lobbying.	3