Neoenergia SA

Neoenergia discloses a broad commitment to conduct its public-policy engagement in line with its climate objectives but provides little insight into the mechanisms that would enforce this alignment. The company notes that "the October 2021 Iberdrola Climate Action document, available on the website, presents how the Group, of which Neoenergia is a part, adheres to the Paris Agreement, and defines its objectives and strategies in line with these" and claims that "for this, it has a robust governance system and specific policies directing the Group's actions." It adds that its Climate Action policy is based on "involving all Interest Groups in its Climate Action strategy, aligned to the 1.5ºC limit" and that the business "participates in activities with stakeholders such as governments, associations, sectoral organizations and other public and private institutions... that may contribute to the fight against climate threats." While these statements indicate an intention to align lobbying with climate goals, the disclosure does not explain how the purported "robust governance system" functions - there is no description of review cycles, escalation or corrective actions, trade-association alignment checks, or an identified board committee or executive accountable for overseeing lobbying activities. Consequently, the evidence shows only a high-level commitment rather than a clearly articulated governance process for managing and monitoring climate-related lobbying.