Public affairs

Stakeholders, public affairs and transparency

Participation in the public life of the communities in which Iberdrola has a presence is an essential facet of its activities. Company engagement with the communities and, at the same time, conveying its positions to the various Stakeholders are two of the objectives of Iberdrola's public activities.

Asuntos Públicos

Iberdrola is regularly present in public and private associations, participates in public consultation processes, and maintains contacts with public administrations, among other activities. This participation is governed by compliance with the laws of each country, as well as with Iberdrola's internal policies and regulations, including, among others:

 

In such activities, Iberdrola assumes and promotes the basic principles of legality, loyalty, trust, professionalism, cooperation, reciprocity and good faith.

In line with its strategy, one of the most significant issues that Iberdrola addresses in its public activities is its role as a driver of an energy transition based on a safe, clean, and competitive system that contributes to a more sustainable future. In this regard, Iberdrola promotes the approval of objectives and frameworks for climate policies in line with the Paris Agreement from an ambitious perspective that creates value for society as a whole. 

Our statement

Nuestra declaración

Transparency

In line with the Iberdrola group's principle of transparency, below is a list of the participation of Iberdrola and the companies of the group in national and international associations and public consultation processes, as well as contacts with regulatory entities and financial contributions to political parties outside of Spanish territory.

This section does not contain information relating to Avangrid in compliance with United States of America legislation, so please refer to Avangrid's corporate website: https://www.avangrid.com/es/public-advocacy

Participation in national and international associations

Iberdrola participates, both at the global level and in the countries in which it has a presence, in various entities and associations defending its business interests and those of its main Stakeholders.

As indicated above, the company decides on its participation in these organisations taking into account consistency with the Corporate Purpose and Values, among which the energy transition and the fight against climate change are of paramount importance.

In 2022, the companies that make up the Iberdrola group participated in 532 organisations, contributing to their support through the payment of membership fees and other items. 

Below is a graph describing the distribution of financial contributions to the associations to which it belonged in 2022:

Numero_de_organizaciones_EN.jpg
This chart does not take into account organisations of which Avangrid is a member due to the legal restrictions mentioned above.

A list of the main national and international associations to which Iberdrola and the companies of its group belonged in 2022 can be found in the Statement of non-financial information.

In this area, the group carries out an annual analysis of the degree of alignment of these organisations with the company's Statement of commitment to sustainable development, respect for and defence of Human Rights and the fight against climate change. 

The group's professionals responsible for the engagement with each association carry out the alignment analysis, taking into account the extent to which the positions and objectives pursued by these organisations and the activities they carry out are consistent with the aforementioned frameworks.

Both the publicly available information on the associations and the knowledge acquired by Iberdrola through participation in their committees and/or working groups are analysed, considering elements such as the real support for the achievement of a net zero emissions target in 2050, the deployment of renewable technologies according to the pace neccesary to achieve this emission reduction and the application of the just transition principles on this path. 

As a result of this assessment, the positioning of the organisations is classified as aligned with, neutral or non-aligned to that maintained by the company in this area, and serves as a basis for decision-making regarding Iberdrola's future participation therein.

It should be noted that this alignment analysis excludes associations in which Avangrid participates as a result of the aforementioned legal restrictions. However, Avangrid's Code of Business Conduct and Ethics includes guidance on participation in political and civic activities, and the company has adopted its Political Education Protocol to assist employees in this area and to ensure that such activities are aligned with the company's stated policies and purpose.

The result of the analysis conducted in 2022 shows that 67%¹  of the organisations in which Iberdrola participates are aligned with the company's Statement of commitment to sustainable development, respect for and defence of Human Rights and the fight against climate change. The remaining cases (33%) correspond to organisations whose alignment has been classified as neutral. 

In these cases, in which there is not complete alignment of the organisations with Iberdrola's position, the company continuously evaluates the suitability of its participation therein in order to defend its thesis and, thus, its interests and those of its Stakeholders. Iberdrola also works actively within them to promote its defence of the Paris Agreement and the energy transition.

In 2022, no organisation in which Iberdrola participates(1) has been identified that has been assessed as being non-aligned to the Statement. 

Asociaciones_nacionales_EN.jpg
(1) This calculation does not include the associations in which the listed subsidiary of the Iberdrola Group in the United States (Avangrid) participates.

Detailed analysis for key organizations and management of misalignment cases 

Based on the global assessment indicated above, Iberdrola delves into a specific analysis of a group of organisations that are particularly relevant for their leadership, influence and contribution to the main processes of developing climate policies and promoting the energy transition. 

This selection includes organizations that meet, totally or partially, different relevant criteria, such as their active participation in the global climate agenda or in the elaboration of the main regulatory packages in the field of energy transition, the presence of global actors in their membership, the leadership exhibited in the international summits on climate change (COPs), the geographical reach of their campaigns and the impact they have on governments and the media.

Taking into account the above, in 2022 Iberdrola carried out a specific analysis of 54 organizations, including industrial and sectoral associations, alliances, foundations, think tanks, NGOs and other international organizations. 

For each of them, this extended analysis specifically details: 

  • the objectives they pursue, 
  • the main advocacy activities in which they have been involved, as well as  
  • the specific role played by Iberdrola in its governing bodies and in the execution of the main activities they carry out. 

The analysis also includes an assessment of the degree of alignment of each organization with the practical implementation of the Paris Agreement and the promotion of the energy transition. To this end, Iberdrola has created an objective and scientifically based analysis methodology that considers elements such as the support granted by the organization to: 

  • the science of climate change, 
  • the achievement of a Net Zero emissions target by 2050, 
  • interim commitments (to 2030) consistent with the 1.5°C target; 
  • and the deployment of green technologies and just transition.

Finally, the conclusions of the analysis also allow us to identify the options available to the company to redirect possible episodes of misalignment between the activities of the organization and the elements indicated above. 

  • For more information on the organizations subject to this detailed alignment analysis click on the  following link [PDF]. 
  • For more information on the methodology used for this analysis and the framework for managing possible episodes of misalignment click on the  following link [PDF].

Participation in public consultation processes

The company also actively participates in the public consultations carried out by regulatory entities to obtain the opinion of the agents involved on regulatory initiatives and national and European energy policies. In addition, it participates in the official processes for processing regulations and in monitoring their application. In all of these processes, Iberdrola states its positions in defence of decarbonisation and the energy transition in legitimate defence of its interests and other Stakeholders.

In some of the markets in which the group is present, these contributions to the legislative process are recorded in public transparency registers that make it possible to know the objectives of each process, as well as the specific contribution made by each organisation.

The main public consultation processes in which the companies of the Iberdrola group participated in 2022 are detailed below.

    • UN High-Level Expert Group on the Net-Zero Emissions Commitments of Non-State Entities’
    • Renewable energy projects - permit-granting processes & power purchase agreements.
    • Revision of EU Ambient Air Quality legislation (Roadmap).
    • Energy Efficiency. Eco-design requirements for water heaters and tanks.
    • Energy Efficiency. Labelling requirements for space and combination heaters.
    • Fit for 55 Package. Regulation establishing a framework for setting ecodesign requirements for sustainable products.
    • EFRAG (European Financial Reporting Advisory Group) Sustainability Reporting Board Consultation Survey on the Draft ESRS (European Sustainability Reporting Standards).
    • ACER (European Union Agency for the Cooperation of Enery Regulators) Public Consultation on the Policy Paper on the revision of NC RfG and NC DC.
    • EU REPower Recovery and Resilience Facility Package. Revenues to finance EU REPower measures.
    • EU REPower Package. Permitting: Renewable Energy Directive review.
    • Delegated acts regarding RFNBOs (Renewable Fuels of Non-Biological Origins).
    • Laying down rules for the application of Regulation (EU) 2018/1999 of the European Parliament and of the Council as regards the structure, format, technical details and process for the integrated national energy and climate progress reports.
    • Review of the default primary energy factor (PEF).
    • Comments on the ERAA (European Resource Adequacy Assessment) 2020 to ACER (European Union Agency for the Cooperation of Energy Regulators).
    • Comments on the draft revised Market Definition Notice.
    • Fit for 55 Package. Proposal on the new EURO 7 standards.
    • Comments on the ERAA (European Resource Adequacy Assessment) 2022 to ENTSOE (European Network of Transmission System Operators for Electricity).
    • Implementation framework for a European platform for the exchange of balancing energy from replacement reserves (RRIF).

    *In its response to these consultations, Iberdrola always authorises their public accessibility. All of them are available through the European Transparency Register or the websites of other European institutions calling for consultation".

    • General framework of the regulatory test bed for the promotion of research and innovation in the electricity sector.
    • Regime for the installation of floating photovoltaic plants in the public water domain. 
    • Low Emission Zones.
    • Remuneration parameters applicable to certain installations for the production of electricity from renewable energy sources, cogeneration and waste.
    • Incentives for heating and cooling network projects using renewable energy sources within the framework of the Recovery, Transformation and Resilience Plan (RTRP).
    • Investment aid for the repowering of wind farms, technological and environmental renovation of mini-hydroelectric plants and innovative wind turbine blade recycling facilities within the framework of the RTRP.
    • Regulatory framework for the development of offshore wind and marine energy installations.
    • Aid for innovative energy storage projects hybridised with electricity generation facilities from renewable sources within the framework of the RTRP.
    • Update of the National Integrated Energy and Climate Plan 2021-2030.
    • Grants for feasibility studies for innovative medium and high temperature geothermal energy projects within the framework of the RTRP.
    • Aid for electricity generation facilities on the islands, based on renewable energy sources, within the framework of the RTRP.
    • Aid for new business model projects in the energy transition within the framework of the RTRP.
    • Rules for the functioning of the daily/intraday electricity markets for their adaptation to the economic regime for renewables and evolution of the agents' committee.

    * The consultation and public participation procedures are available through the websites of the organisations that have launched them. In Spain: www.miteco.gob.es and www.cnmc.es 

    • Energy pricing and energy market reform.
    • Warm Home Discount Scheme Scotland.
    • Energy Bills Support Scheme.
    • UK Emissions Trading Scheme.
    • Decarbonisation of the power sector.
    • Delivering a smart and secure electricity system.
    • Review of electricity market agreements.
    • Review of the Net Zero strategy.
    • Proposals for hydrogen transport and storage business model.
    • ECO+ Programme aimed at improving energy efficiency and reducing electricity bills through insulation measures in homes.
    • Adaptation of the methodology for setting a price cap in gas and electricity markets to enhance resilience to volatility and improve consumer protection.
    • Future of the retail energy market.
    • Consultation on medium-term changes to the methodology for setting a price cap methodology.
    • Consultation on changes to the market stabilisation charge.
    • True-up process for COVID-19 costs.
    • Price cap. Possible wholesale cost adjustment.
    • Price cap. Changes to the wholesale methodology.
    • Locational pricing assessment.
    • Supplier control over material assets.
    • Strengthening financial resilience.

    * The consultation and public participation procedures are available through the websites of the launching organisations. In the UK: www.gov.scot, www.ofgem.gov.uk and www.gov.uk  

    • Creation of the single portal for the management of offshore areas.
    • Guidelines for the consideration of environmental benefits in the electricity sector including the creation of carbon markets. 
    • Market opening for low voltage consumers.

    * The consultation and public participation procedures are available through the websites of the organisations that have launched them. In Brazil: Ministério de Minas e Energia

  • Iberdrola Mexico has not participated in public consultation processes during the financial year.

  • Information about Avangrid is available on its corporate website. 

Contacts with public bodies

Iberdrola maintains regular contact with public bodies in order to convey its views and defend its business interests and those of its shareholders and customers. These contacts take various forms, ranging from face-to-face meetings with representatives of public administrations to the signing of agreements for cooperation and participation in initiatives and projects of common interest.

The most significant milestones in Iberdrola's activity in 2022 in this area are set out below:

  • In 2022, company representatives held meetings with members of the Vice-Presidencies of the European Commission, as well as the Directorates-General for Energy; Climate; Internal Market and Environment. These meetings were related to areas such as the following:

    • Maritime spatial planning and coexistence of uses.
    • Energy crisis and transition to clean energy.
    • Energy prices.
    • Action Plan for the Digitalisation of the Energy Sector.
    • Methods to boost the manufacture and deployment of solar photovoltaic panels in the European Union.
    • RePowerEU Programme.
    • European Taxonomy of Environmentally Sustainable Activities.
    • Proposals in the framework of the Fit-for-55 Programme.
    • Renewable Hydrogen.
    • Innovation on clean technologies.

  • In 2022, relations with state public administrations involved contacts with the ministries related to the sector and their technical departments, especially the Ministry for Ecological Transition and the Demographic Challenge (Ministerio para la Transición Ecológica y el Reto Demográfico - MITECO).  

    Likewise, the competent energy regulator (Spanish National Markets and Competition Commission - CNMC), the Institute for the Diversification and Saving of Energy (IDAE) were agents with whom the company interacted and collaborated closely throughout the year.

    As in other markets, 2022 was a year of great complexity in the energy sector, which led to intense regulatory activity. In this context, the main contacts with the aforementioned bodies focused on the following issues:

    • Energy crisis and proposals to alleviate its consequences in the short and long term.
    • Long-term storage and capacity mechanisms.
    • Impact of proposals for a special windfall profit tax and other intervention measures.
    • Reform of the PVPC regulated tariff.
    • Methodology for financing the Social Bonus.
    • Accelerating the deployment of renewables.
    • Appropriate recognition of network investments.
    • Next Generation Programme funds.
    • Grid access for renewable energy installations.
    • Promotion of Electric Mobility.

    For its part, the company's engagement with regional and local institutions focused on areas such as the following: 

    • Energy planning, especially with regard to the deployment of renewable technologies and grid development.
    • Authorisation processes for renewable installations, recharging points and other infrastructures.
    • Regional climate change strategies.

  • Scottish Power makes frequent contacts at corporate or business level with UK public institutions at national, regional or local level.

    At the national level, the company maintained ongoing relations with various ministries, the energy regulator (Ofgem) and other public servants.

    The interactions carried out, in the context of a year of great complexity in the energy sector, involved issues such as the following: 

    • Energy Security Strategy.
    • Energy price caps and rising energy bills and proposals for short and long term relief.
    • Possible "extraordinary tax" on renewable generation.
    • Acceleration in the deployment of renewable energies. 
    • Need for agile regulation to support the network investment process. 
    • Acceleration in the planning of all infrastructure to support decarbonisation targets.
    • Review of electricity market agreements. 
    • Energy efficiency.
    • Green hydrogen policy.
    • Business participation in COPs 26 and 27 on climate change.
    • Proposals for a new energy bill.

    In addition, ScottishPower has interacted with representatives of regional and local public administrations. The main issues addressed throughout 2022 were as follows: 

    • Planning related to renewable energy deployment and grid development.
    • Decarbonisation goals, covering heat, transport, green hydrogen and net zero emission targets.
    • ScotWind programme enabling wind developers to apply for offshore land use rights to plan and construct facilities in Scottish waters.
    • Thermal and energy efficiency policies and programmes.
    • Environmental issues.
    • Circular economy.

  • Throughout 2022 Neoenergia has participated in various institutional activities that have involved contact with members of the federal and national public administrations, the national operator of the electricity sector (ONS) and the national electricity agency (ANEEL). The main issues discussed in these meetings were:

    • Establishment of incentives for sustainable hydrogen use.
    • Granting of authorisations to exploit offshore wind potential.
    • Possibility of association of wind farms and photovoltaic plants to take advantage of the complementarity between sources and promote the optimisation of the use of the transmission system.
    • Regulation of the procedures and criteria for the calculation and payment of supply restrictions (constrained-off) for wind and photovoltaic plants.
    • Regulatory adjustments necessary for the insertion of storage systems, including reversible plants, in the National Interconnected System.
    • Sectoral climate change mitigation plans and national greenhouse gas emission reduction system.
    • Draft Law on the Brazilian Emission Reduction Market.
    • Projects promoted by Iberdrola within the R&D programme of the National Electricity Agency.

    In addition, Neoenergia has collaborated with Brazilian public administrations in the promotion of certain strategic initiatives related to green hydrogen and the promotion of offshore wind energy. In 2022, the company collaborated with various stakeholders in the promotion of more than 15 projects in this area.

  • Iberdrola Mexico has not maintained this type of contact during the year.

  • Information about Avangrid is available on its corporate website.

Financial contributions to political parties

Iberdrola is a politically neutral company. 

In Spain, contributions to political parties are prohibited by the Code of Ethics.

In the financial year 2022, none of the group companies, with the exception of the United Kingdom, the United States and Australia, contributed to the financing of political parties.

In the Non-Financial Information Statement of the company more information could be found at this respect. 

Coordination of climate action at the company 

Iberdrola has an internal climate change working group that ensures the coordination and exchange of information regarding the company's climate action. All jurisdictions and relevant corporate areas, including communication, legal services, ESG, investor relations, regulation, etc., participate in this group. The group reports on the main milestones and progress relating to the global climate agenda as well as those relating to the main countries and areas (European Union) of interest to Iberdrola. It also sets out the lines of action followed and the strategies adopted for Iberdrola's participation in the main conversations, campaigns, high-level and technical forums, as well as in public consultation processes in the area of climate action.                                    

The climate change working group is a very useful tool for coordinating positions and actions internally, as well as for sharing and exchanging relevant information regarding climate action to be taken into account by the various areas and jurisdictions. This effort to coordinate and share information makes it possible to analyse the degree of alignment of the Company's actions with the objectives of the Paris Agreement and the promotion of the energy transition, as well as to ensure that this alignment is maintained in all cases – in accordance with the provisions of corporate policies.