ERG SpA

ERG SpA provides limited detail on its lobbying governance processes. It indicates that "we adopted an in-house control system based on procedures integrated into the Organisational Model (pursuant to Italian Legislative Decree 231/01 as amended) and supported by a specific system of sanctions" to govern its relations with institutional stakeholders and enforces a policy stating that "no direct or indirect contributions may be paid...to political parties, movements, committees, political organisations, or trade unions." Its Code of Ethics mandates that "all relationships and contacts with public institutions...shall be managed by the business units formally in charge of keeping contacts with those institutions" to promote transparency. The company asserts that "all the engagement activities with our stakeholder...are coherent with the Paris Agreement" and outlines various methods of influencing policy, including participation in trade-association bodies and "legitimate lobbying activities directly or in association with other energy operators." However, ERG SpA does not disclose any specific individual or formal body responsible for overseeing or reviewing lobbying alignment, nor does it describe a defined process for monitoring how its direct and indirect lobbying activities are aligned with its climate strategy.