Gerdau SA

Gerdau discloses that a "corporate Institutional Relations department, in addition to teams specialized in the subject, such as the Environment and Engineering team and an ESG Squad" is responsible for engagement, and that "they jointly assess the consistency of the actions with the Company's policy," indicating an internal mechanism that reviews whether its policy advocacy aligns with company positions. The same passage notes that these teams oversee involvement in external bodies such as "CNI, IABR, Worldsteel, and FGV's Business Initiatives," showing some attention to the alignment of indirect lobbying through trade associations. While this demonstrates a defined process and identifies a formal internal body charged with oversight, the company does not disclose how often the assessments occur, the criteria used, any escalation to the board or senior executives, or the way direct lobbying is monitored and corrected, nor does it publish the outcomes of these reviews; thus, transparency and depth of the governance framework remain limited.