Naturgy Energy Group SA

Naturgy has established a foundational governance framework for its climate-related policy engagement through its "Global Policy on Institutional Relations," which applies to "all interactions with authorities, public officials and political parties, carried out directly or through associations, foundations or other third parties." In 2020 it undertook a review to "analyse the position in these areas of the main entities in which the company participates" and found that none were misaligned with its climate commitments. During 2021, it has been "updating its Institutional Relations Policy, which, once approved, will incorporate verification requirements regarding positioning in the fight against climate change, as a prior step to joining new associative entities," making "participation in entities or alliances with third parties conditional upon their alignment with the climate policies emanating from the Paris Agreement." These measures are reinforced by a public commitment within its Environmental Policy to "promote, directly and through alliances with other actors, climate policies aligned with the Paris Agreement, ensuring permanence only in the trade associations that meet this criterion and publish an annual list of them." However, the company does not disclose how these verification requirements will be operationally implemented or monitored, offers no details on governance of its direct lobbying activities, and provides no indication of a specific individual or formal body responsible for overseeing alignment of its lobbying with climate objectives.