Hera SpA

Hera SpA has established a governance process that centralizes oversight of its engagement activities to align with its climate change strategy by ensuring that "relations are mainly managed indirectly through trade associations" and concentrating stakeholder relations "in Hera organization in staff to either the Executive Chairman or the CEO ... to assure consistency of activities with climate change strategy of the Group." The company further details that "Investor Relations, Shared Value and Sustainability Department, Relations with Authorities and Public Affairs are the functions in charge of sharing and discussing Hera's position on environmental and climate change issues with all relevant stakeholders," and notes that "Hera's discussions with the main public bodies and associations are often carried out by the BoD Executive Chairman and/or the CEO themselves." This indicates strong governance of both direct and indirect lobbying activities, with clear assignment of responsible executives and functions. However, the company does not disclose a formal review or monitoring procedure, criteria for assessing its participation in trade associations, or a recurring audit or board sign-off process to systematically verify and enforce alignment.