Terna Energy SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Terna Energy discloses several mechanisms that demonstrate it seeks to keep its policy engagement in line with its climate strategy. It states that "We examine very carefully through a due diligence process the trade associations we engage with. The due diligence is being performed by our Legal department," indicating a concrete review step for indirect lobbying and naming the Legal department as the responsible function. For direct advocacy, the company notes that "The monitoring of legislative activities and regulations (included the regulation on climate change) is the responsibility of the company specific functions in the Department of Institutional Affair" and that it has created "the Brussels Office to monitor its activities in a structured and coordinated way in order to ensure uniform and consistent participation" with European institutions on energy-transition issues, showing an internal process to oversee and align its own lobbying. In addition, Terna confirms that it has "a public commitment to conduct your engagement activities in line with the goals of the Paris Agreement." Terna Energy has disclosed about its climate policy alignment with 11 trade associations, stating that its positions are consistent and that they are not trying to influence them. However, the disclosure does not provide details of how misalignment is assessed or remedied, nor does it publish a formal lobbying-alignment report; the company also does not disclose whether the due-diligence findings or legislative-monitoring outcomes are regularly reviewed or made public. Consequently, while the evidence points to moderate governance with defined processes for both direct and indirect lobbying, the absence of higher-level oversight and transparent reporting suggests the governance framework is not yet comprehensive. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Terna Energy discloses several mechanisms that demonstrate it seeks to keep its policy engagement in line with its climate strategy. It states that "We examine very carefully through a due diligence process the trade associations we engage with. The due diligence is being performed by our Legal department," indicating a concrete review step for indirect lobbying and naming the Legal department as the responsible function. For direct advocacy, the company notes that "The monitoring of legislative activities and regulations (included the regulation on climate change) is the responsibility of the company specific functions in the Department of Institutional Affair" and that it has created "the Brussels Office to monitor its activities in a structured and coordinated way in order to ensure uniform and consistent participation" with European institutions on energy-transition issues, showing an internal process to oversee and align its own lobbying. In addition, Terna confirms that it has "a public commitment to conduct your engagement activities in line with the goals of the Paris Agreement." Terna Energy has disclosed about its climate policy alignment with 11 trade associations, stating that its positions are consistent and that they are not trying to influence them. However, the disclosure does not provide details of how misalignment is assessed or remedied, nor does it publish a formal lobbying-alignment report; the company also does not disclose whether the due-diligence findings or legislative-monitoring outcomes are regularly reviewed or made public. Consequently, while the evidence points to moderate governance with defined processes for both direct and indirect lobbying, the absence of higher-level oversight and transparent reporting suggests the governance framework is not yet comprehensive.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Terna Energy provides a solid level of transparency around its climate-policy lobbying. It names a range of specific legislative files it has engaged on, including the “EU Taxonomy Regulation,” the “Corporate Sustainability Reporting Directive,” the “Fit for 55 package,” the “EU Green Bond Standard,” and Greece’s “National Plan for Energy and Climate,” making it clear which measures are the focus of its advocacy. The company also explains how and where it lobbies: it “actively collaborated through its Function ‘EU Institutional Affairs’ based in Bruxelles,” worked “in collaboration with the main trade associations of which it is a member (ENTSO-E; Sustainable finance corporate forum),” and produced “position papers on the most relevant measures” for EU policymakers, showing both direct engagement with EU institutions and indirect engagement via industry associations. On policy positions, Terna Energy states that it “support[s] with no exceptions” the Corporate Sustainability Reporting Directive and the EU Green Bond Standard and expresses overall support for the Fit for 55 package and the national energy and climate plan, demonstrating clear—if largely affirmative—outcomes it seeks, even though it does not always spell out detailed amendments or quantitative targets. Together, these disclosures demonstrate strong, though not exhaustive, transparency across policies lobbied, mechanisms used, and outcomes sought.	3