Santos Brasil Participacoes SA

Santos Brasil discloses only a high-level commitment to align its policy engagement with climate goals, stating that it "se comprometeu publicamente com a reduçã o de suas emissões de gases de efeitos estufa" and confirms it "has a public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement." This indicates the company recognizes the need for consistency between advocacy and climate strategy, but it does not elaborate on any internal mechanisms, oversight bodies, monitoring procedures, or processes to enforce that alignment. We found no evidence of a named individual or committee overseeing lobbying, no description of how direct or trade-association lobbying is reviewed, and no mention of audits or corrective actions, suggesting that the disclosed governance of climate-related lobbying remains limited to a general policy commitment rather than a defined governance framework.