Anima Holding SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Anima Holding discloses a formal “Politica d’impegno” that governs how the group engages with investee companies and, where necessary, with “emittenti di titoli governativi e di organismi regolatori”, and states that this policy is “aggiornata almeno annualmente e pubblicata sul proprio sito internet”, demonstrating that engagement-and-influence activities are managed through a recurring, board-approved process. Oversight responsibilities are described in detail: the “Consiglio di Amministrazione… verifica periodicamente la corretta attuazione della Policy”, the “Comitato ESG… effettua il monitoraggio periodico” of ESG criteria, and the “Servizio Investment Principles… svolge attività di engagement e ne monitora gli esiti”. This structure shows that specific internal bodies are tasked with supervising and reviewing how engagement (which includes influencing regulators) is conducted and whether it aligns with the ESG policy, fulfilling key elements of a lobbying-governance framework. However, the disclosures remain focused on general ESG stewardship and voting; we found no evidence of a dedicated process for assessing the climate-specific alignment of direct lobbying positions, no reference to reviewing or managing the company’s membership in trade associations, and no public lobbying-alignment report or third-party audit. Consequently, while the company provides a clear governance mechanism for engagement and some environmental objectives are embedded in that process, the depth and climate-specific scope of its lobbying governance are limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Anima Holding discloses a formal “Politica d’impegno” that governs how the group engages with investee companies and, where necessary, with “emittenti di titoli governativi e di organismi regolatori”, and states that this policy is “aggiornata almeno annualmente e pubblicata sul proprio sito internet”, demonstrating that engagement-and-influence activities are managed through a recurring, board-approved process. Oversight responsibilities are described in detail: the “Consiglio di Amministrazione… verifica periodicamente la corretta attuazione della Policy”, the “Comitato ESG… effettua il monitoraggio periodico” of ESG criteria, and the “Servizio Investment Principles… svolge attività di engagement e ne monitora gli esiti”. This structure shows that specific internal bodies are tasked with supervising and reviewing how engagement (which includes influencing regulators) is conducted and whether it aligns with the ESG policy, fulfilling key elements of a lobbying-governance framework. However, the disclosures remain focused on general ESG stewardship and voting; we found no evidence of a dedicated process for assessing the climate-specific alignment of direct lobbying positions, no reference to reviewing or managing the company’s membership in trade associations, and no public lobbying-alignment report or third-party audit. Consequently, while the company provides a clear governance mechanism for engagement and some environmental objectives are embedded in that process, the depth and climate-specific scope of its lobbying governance are limited.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Anima Holding SpA offers only limited visibility into its climate-related lobbying. It references participation in broad initiatives such as the Global Investor Statement to Governments on the Climate Crisis and support for the EU Corporate Sustainability Reporting Directive, but it does not systematically list the individual climate laws or regulations it tries to influence, making it hard to understand the exact policy agenda it pursues. The company outlines a handful of channels it uses—signing collective letters, taking part in public consultations, voting at investee company meetings, and engaging through industry groups—yet it rarely specifies whom these efforts are directed at beyond a general reference to “EU legislators,” “regulators,” or “policy makers.” Its stated aims remain aspirational, centring on stronger sustainability reporting standards, alignment with the Paris Agreement, and reduced greenhouse-gas emissions, without detailing the concrete legislative changes, targets or timelines it seeks. This combination of high-level references and absent detail means stakeholders receive only a cursory picture of Anima’s climate-policy lobbying intentions and activities.	D