Sacyr SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Sacyr SA has established a structured governance framework to ensure its lobbying and policy-influencing efforts are aligned with its 2021 “Corporate Climate Change Strategy,” which “takes into account all of Sacyr’s business areas and activities in the definition of targets and action lines, including its engagement approach.” To enforce alignment, the company requires “new activities will require the acceptance of at least one of these committees” and has set up “the Sustainability and Corporate Governance Committee, a delegate committee of the Board of Directors, and the Sustainability Committee, which are the most senior bodies responsible for ESG-related matters,” as well as a Management System Committee. The governance process includes “the annual monitoring of the Sacyr Sustainable Action Plan” where “each area involved reports the extent of their progress ... to the Strategy, Innovation and Sustainability Department, which in turn reports the global progress to the Sustainability Committee and the Sustainability and Corporate Governance Committee,” demonstrating clear oversight, sign-off and monitoring mechanisms. The company explicitly states that “all of its direct and indirect activities are consistent with its overall climate change approach” and holds a “public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement.” We found no evidence of a publicly available audit or third-party review specifically assessing the alignment of its climate-related lobbying activities, indicating that formal external verification of its lobbying governance is not disclosed. View Sources	3

Overall Assessment

Analysis

Score

Strong

Sacyr SA has established a structured governance framework to ensure its lobbying and policy-influencing efforts are aligned with its 2021 “Corporate Climate Change Strategy,” which “takes into account all of Sacyr’s business areas and activities in the definition of targets and action lines, including its engagement approach.” To enforce alignment, the company requires “new activities will require the acceptance of at least one of these committees” and has set up “the Sustainability and Corporate Governance Committee, a delegate committee of the Board of Directors, and the Sustainability Committee, which are the most senior bodies responsible for ESG-related matters,” as well as a Management System Committee. The governance process includes “the annual monitoring of the Sacyr Sustainable Action Plan” where “each area involved reports the extent of their progress ... to the Strategy, Innovation and Sustainability Department, which in turn reports the global progress to the Sustainability Committee and the Sustainability and Corporate Governance Committee,” demonstrating clear oversight, sign-off and monitoring mechanisms. The company explicitly states that “all of its direct and indirect activities are consistent with its overall climate change approach” and holds a “public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement.” We found no evidence of a publicly available audit or third-party review specifically assessing the alignment of its climate-related lobbying activities, indicating that formal external verification of its lobbying governance is not disclosed.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Sacyr SA demonstrates strong transparency around its climate lobbying activities. It names two specific climate-related policies by title: the Draft Royal Decree Approving the Regulation on the Tax on Fluorinated Greenhouse Gases and the Draft Royal Decree regulating climate-related financial impact reporting under law 7/21. It clearly lays out its engagement mechanisms, explaining that it "has been involved by sending general comments towards the drafting of the Royal Decree Project in coordination with the Department of Industry, Energy, Environment and Climate," participated in the formal consultation in collaboration with the Spanish Confederation of Business Organisations (CEOE), and drafted consensus comments for the CEOE’s submission. It also articulates multiple concrete outcomes it seeks, including introducing greater simplicity to the tax to ensure better compliance, supporting the tax “with no exceptions,” encouraging “the use of safe and energy-efficient alternative technologies with zero or less impact on the climate,” and reinforcing alignment with the Paris Agreement by incorporating climate and carbon risk disclosures for financial institutions. This level of detail across policy, mechanism, and sought outcomes demonstrates a high level of transparency in Sacyr SA’s climate lobbying disclosures.	3