SIMPAR SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	SIMPAR discloses several elements that indicate a structured approach to managing its interactions with policymakers, yet the information is still only moderately detailed on how those mechanisms specifically secure alignment with the Group’s climate positions. The company explains that it “collaborates with the development of public actions and policies… through participation in sectoral associations,” and states that it has “a public commitment … to conduct [our] engagement activities in line with the goals of the Paris Agreement.” Governance of this engagement sits within the wider compliance architecture: “Ethical governance at SIMPAR occurs in a robust manner, with an independent Internal Controls, Risks and Compliance Board (CRC), which operates across the Group and reports to the holding’s Audit committee,” while “SIMPAR’s Compliance Program is equipped with policies… reviewed in 2023 by the Ethics and Compliance Committee, with final approval by the Board of Directors.” Among the policies listed is a “Policy for Interaction with Public Authorities (revised in 2023),” suggesting a formal rule-set for lobbying conduct, and the company notes that these procedures have been “inserted into DocNix, a document management tool” to standardise implementation across subsidiaries. SIMPAR also states that it “estud[a], analis[a] e monitor[a] legislação related to climate and environmental issues” and that it participates in the CEBDS climate, energy and sustainable finance working groups to help ensure consistency between engagement activities and its climate commitments. However, the disclosure does not set out a clear process for assessing the climate-policy positions of each trade association, nor does it describe any mechanism for correcting or exiting misaligned associations, and there is no dedicated, recurring review or public report on climate-lobbying alignment. Consequently, while the presence of board-approved policies and an identified oversight structure indicates stronger governance than a minimal approach, the limited detail on how direct and indirect lobbying is formally monitored for climate alignment means the company only demonstrates a moderate level of lobbying governance transparency. View Sources	C

Overall Assessment

Analysis

Score

Moderate

SIMPAR discloses several elements that indicate a structured approach to managing its interactions with policymakers, yet the information is still only moderately detailed on how those mechanisms specifically secure alignment with the Group’s climate positions. The company explains that it “collaborates with the development of public actions and policies… through participation in sectoral associations,” and states that it has “a public commitment … to conduct [our] engagement activities in line with the goals of the Paris Agreement.” Governance of this engagement sits within the wider compliance architecture: “Ethical governance at SIMPAR occurs in a robust manner, with an independent Internal Controls, Risks and Compliance Board (CRC), which operates across the Group and reports to the holding’s Audit committee,” while “SIMPAR’s Compliance Program is equipped with policies… reviewed in 2023 by the Ethics and Compliance Committee, with final approval by the Board of Directors.” Among the policies listed is a “Policy for Interaction with Public Authorities (revised in 2023),” suggesting a formal rule-set for lobbying conduct, and the company notes that these procedures have been “inserted into DocNix, a document management tool” to standardise implementation across subsidiaries. SIMPAR also states that it “estud[a], analis[a] e monitor[a] legislação related to climate and environmental issues” and that it participates in the CEBDS climate, energy and sustainable finance working groups to help ensure consistency between engagement activities and its climate commitments. However, the disclosure does not set out a clear process for assessing the climate-policy positions of each trade association, nor does it describe any mechanism for correcting or exiting misaligned associations, and there is no dedicated, recurring review or public report on climate-lobbying alignment. Consequently, while the presence of board-approved policies and an identified oversight structure indicates stronger governance than a minimal approach, the limited detail on how direct and indirect lobbying is formally monitored for climate alignment means the company only demonstrates a moderate level of lobbying governance transparency.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	SIMPAR provides a fair amount of detail on its climate-policy lobbying. It names two concrete policy engagements: its participation in discussions on “Artigo 6° do Acordo de Paris” and the formal “document in defense of the Amazon” that it submitted on 6 July 2020 to Brazil’s Supreme Federal Court, Federal Senate, Chamber of Deputies, Office of the Prosecutor-General and the Vice-President. The company is particularly clear about the channels it used, combining indirect advocacy through the “grupo de empresários líderes que solicitaram aos governos transição para uma economia de baixo carbono através do Posicionamento Empresários pelo Clima liderado pelo CEBDS,” direct representation at COP27, and the formal delivery of its Amazon position paper to named federal institutions—demonstrating three distinct mechanisms and identifying the precise governmental targets. By contrast, the objectives it seeks remain broad: it speaks of “Incentivar a elaboração de políticas públicas relacionadas às mudanças climáticas,” supporting the transition to a low-carbon economy and protecting the Amazon so that Brazil can meet its climate commitments, but it does not spell out specific legislative amendments, quantitative targets or timelines. Overall, the company is moderately transparent, clearly outlining who it lobbies and on which issues, while providing only high-level statements about the outcomes it intends to achieve.	C