Italgas SpA

Italgas discloses a structured process to govern its indirect lobbying through trade associations by applying a "dual approach" under which "each new membership proposal is examined to assess (1) its consistency with Italgas' strategic objectives, including those related to climate change ... (4) the economic and human resources effort" and by ensuring that "the planning documents and position papers drafted by the associations are analyzed and if necessary ... amended ... to ensure consistency with Italgas' strategic positions and views to fight climate change." Oversight of this work is provided by the Sustainable Value Creation Committee, which "examines any sustainability initiative in agreements submitted to the BoD, also as to the subject of climate change ... and the gas advocacy of the Group," and the Board of Directors is periodically informed of these reviews. The company also publicly commits that "We carry out engagement initiatives and pursue our sustainability objectives in line with the commitments set out in the Paris Agreement." However, Italgas does not disclose any equivalent alignment process or oversight for its direct lobbying activities, nor does it name a specific individual responsible for reviewing lobbying alignment or describe board sign-off of climate-related lobbying plans.