Petroleo Brasileiro SA

Petróleo Brasileiro SA discloses a climate-focused governance structure that implicitly covers policy engagement, stating that it has "built a governance with discussion and deliberation forums that perpasses all levels of the company, all of them with the participation of Climate Change Executive Management," whose role is "to conceive and coordinate the positioning, strategies, and corporate actions related to climate change." Oversight is anchored at board level, where "the monitoring of the ESG commitments and goals...is carried out by the Health, Safety, and Environment Committee (CSMS), which is responsible for advising the BoD on the establishment of policies and guidelines related to ESG, including...climate change," and complemented by "the Executive Committee for Safety, Environment, and Health (CE-SMS)" that supports the Executive Board. The company adds that "people assigned to participate in engagement activities are conscious of its objectives" and that "we evaluate our engagement alignments," indicating an internal process to check that external advocacy remains consistent with its climate strategy. However, the disclosures do not detail how these committees specifically monitor or approve direct lobbying actions, nor do they describe any systematic review of indirect lobbying through trade associations or the publication of an external alignment report, leaving the scope and rigour of the process unclear. Overall, the company demonstrates a defined governance framework and named oversight bodies for aligning climate-related engagement, but the lack of explicit procedures for lobbying channels and absence of public alignment reviews suggest only moderate transparency and robustness.