Cementos Argos SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Cementos Argos SA is highly transparent about its climate-related lobbying. It names multiple identifiable policies it has worked on, including the “Second version of the decree adopting provisions aimed at the implementation of Carbon Capture, Utilization, and Storage (CCUS) technologies,” the Colombian government’s “Roadmap for a just energy transition,” the U.S. “Inflation Reduction Act,” a Colombian “Resolution regulating the conditions, criteria and requirements for validation and verification processes in greenhouse gas mitigation initiatives,” reform of Colombia’s national carbon tax, and frameworks such as the Regional Emission Reduction Mechanism and proposals for an Emissions Trading System. The company also gives clear detail on how and where it lobbies: it describes “responding directly to consultations made by the Ministry of Mines and Energy,” holding “meetings with members of Congress,” appearing before a U.S. Senate Environment and Public Works hearing through the Portland Cement Association, and working through trade and industry bodies such as ANDI, PROCEMCO, PCA, GCCA and FICEM to submit comments, review draft regulations and participate in technical working groups with the Colombian Ministries of Environment, Housing and Mines and Energy. Finally, Argos sets out the concrete outcomes it seeks, for example advocating to “promote waste co-processing as a climate change mitigation strategy,” opposing a U.S. House amendment that would limit the use of low-carbon concrete, pressing for Environmental Product Declarations to shift to a cradle-to-cradle boundary, supporting the CCUS decree “with minor exceptions” while calling for “other sectors [to be] included in the scope of the regulation,” and proposing an “alternative policy: Term extension for implementation and elimination of carbon tax once the Colombian Emissions Trading System (ETS) is in place.” By providing this level of specificity on the policies addressed, the channels and targets of engagement, and the precise legislative or regulatory changes it is advocating, the company demonstrates comprehensive transparency around its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Cementos Argos SA has instituted a governance framework to align its lobbying activities with its climate objectives, particularly focusing on its indirect lobbying through trade and industry associations. The company’s Code of Business Conduct “defines the governance framework for stakeholder engagement and covers all jurisdictions where we have operations and guides our lobbying activities and trade and industry association memberships,” and its Anticorruption Policy enshrines a “zero tolerance attitude to corruption” for both lobbying and charitable contributions. To ensure associations’ positions align with the Paris Agreement, Argos mandates that lobbying is “carried out through trade and industry associations that represent and promote key issues for our company, including climate change and activities aligned with the Paris Agreement,” and that these associations “were assessed by reviewing their public positions using their websites, media releases, publications, social media, and, when needed, discussions with the employees who have a relationship with the trade associations.” Oversight of engagement approval, progress monitoring, and result validation is assigned to its Corporate Affairs Vice President, who is “responsible for approving the engagement, monitoring the progress, and approving the results.” While these procedures demonstrate clear processes and a designated senior officer for indirect lobbying, the company does not disclose any equivalent governance for its direct lobbying activities or a publicly available audit of its climate-related lobbying alignment.	2