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Almawave’s governance disclosures describe its corporate oversight structure under the traditional Italian model, where “the Board of Directors [is] the fulcrum of the organizational system” and the Board of Statutory Auditors exercises supervisory functions, supported by an “Organizational Model 231, composed of a set of behavioral norms, processes, procedures, and policies” overseen by a “Supervisory Body, specifically tasked with overseeing the functioning and compliance of the adopted Organizational Model and ensuring its periodic updates,” and the annual “Sustainability Report” that the Board analyzes and approves to disclose environmental, social, and economic performance. However, we found no evidence of any governance mechanisms for lobbying activities, as there is no disclosure of how direct or indirect lobbying is monitored, no processes for aligning lobbying with climate policy, and no designated individuals or formal bodies overseeing lobbying alignment.
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