Snam SpA

Snam SpA demonstrates a comprehensive climate lobbying governance process that integrates transparency, accountability, and alignment with its climate-related goals. The company has introduced a Climate Lobbying Policy in 2023, which outlines "the principles underlying the Group's climate strategy, advocacy position and affiliations with associations: the six Key Climate Advocacy Drivers." This policy is supported by robust oversight mechanisms, including the Board of Directors, which "plays a central role in overseeing the climate change strategy" and periodically reviews and approves climate-related targets, strategic plans, and monitoring indicators. The Board is supported by three internal committees, including the Environmental, Social & Governance and Energy Transition Scenarios Committee, which examines "long-term energy transition scenarios underpinning the Strategic Plan" and monitors the decarbonization roadmap. Furthermore, Snam has established processes to ensure alignment of external engagement activities with its climate commitments, such as "an annual monitoring activity carried out by the competent functions along with the Institutional Affairs function to guarantee the alignment of the association's memberships with the business objectives, including those related to the climate change commitment." The company also discloses its climate-related lobbying activities and assesses their alignment with the Paris Agreement objectives, demonstrating "clear commitment to climate goals." Additionally, Snam has implemented internal procedures for managing relations with associations, including evaluations to assess alignment with climate goals and sustainable principles, and has committed to "expose our point of view and our disagreement and, in case, we consider to exit from the Association" in cases of misalignment. This indicates a robust governance framework that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms, accountability structures, and public transparency in place.