Alstom SA

Alstom discloses a basic governance structure that seeks to keep its policy advocacy consistent with its climate objectives, noting that it "communicates about its climate-related engagement activities in its URD... in the section 'Relations with governments, international & national organisations and think tanks'" and that it has processes "to ensure that your engagement activities are consistent with your overall climate change strategy." The company sets out clear internal rules for any lobbying, stating that "All lobbying must advance sound public policies," that "outside lobbyists are strictly limited, subject to stringent approval and thorough due diligence by the Ethics and Compliance Department," and that gifts or hospitality to officials must follow anti-corruption rules, which indicates the presence of procedural controls and a named oversight body. It also reports that it files "public filings quarterly to the U.S. Congress, New York State Joint Commission on Public Ethics and LA Metro Ethics Department" and complies with Canadian disclosure requirements, suggesting an operational mechanism for monitoring direct lobbying. In addition, the company makes "a public commitment... to conduct your engagement activities in line with the goals of the Paris Agreement," evidencing an intention to align advocacy with climate goals. However, the disclosures do not explain how the Ethics and Compliance Department assesses whether specific positions or trade-association memberships are aligned with Alstom's climate strategy, and we found no evidence of a formal, recurring review of indirect lobbying or of board-level oversight. The absence of any published alignment audit or description of corrective actions when misalignment is identified means the governance framework remains limited to internal compliance controls rather than a comprehensive climate-lobbying alignment process.