AerCap Holdings NV

AerCap requires "prior approval is required for any intended communication with a DPO that potentially constitutes lobbying activity" and discloses all such interactions in the central Irish lobbying register, noting that "all lobbying activities were properly disclosed" in its statutory filings. The company has established a "dedicated government affairs function based in Brussels, focused on legislative developments and strategic matters ... focusing on aircraft leasing, air transport, aviation sustainability and ESG" and reports that its "Board-level ESG Committee provides oversight of ESG risks and opportunities at the highest level." However, we found no evidence of a policy or procedure designed to align the company's lobbying specifically with climate or Paris-aligned objectives - indeed, the company states "No, and we do not plan to have one in the next two years" with respect to a Paris-Agreement position - and it does not identify any formal climate-lobbying review process or a named individual tasked with ensuring climate-related lobbying alignment beyond its general compliance and ESG oversight mechanisms.