Rumo SA

Rumo discloses a limited process for ensuring that its public-policy engagement aligns with its climate objectives, noting that it "describe[s] the process... to ensure that your engagement activities are consistent with your overall climate change strategy" and that a "multidisciplinary group formed by areas such as Sustainability, Energy Efficiency and Operations... meets every two weeks and is responsible for conducting the company's strategy in relation to climate change." The company also states that it "has a public commitment... to conduct [its] engagement activities in line with the goals of the Paris Agreement" and participates in the "CEBDS Climate Change Working Group, which is responsible for issuing public position statements [and] public policies." These disclosures indicate an intention to align external advocacy with climate strategy and show at least one internal forum that reviews such engagement. However, the evidence does not disclose any formal governance mechanism that explicitly oversees lobbying activities, no description of how direct or indirect lobbying is monitored or audited, no references to assessing trade-association positions, and no identification of a specific board committee or executive who signs off on lobbying alignment. Consequently, while there is some acknowledgement of climate-aligned engagement, the overall lobbying-governance framework remains largely undeveloped and lacks transparency on oversight, monitoring procedures and accountability for lobbying alignment.