Boston Scientific Corp

Boston Scientific discloses a basic framework intended to keep its policy engagement in line with its climate strategy, stating that "our overall climate strategy ... is considered at the onset of all activities that influence policy" and that such activities are "supported by our ESG Executive Steering Committee" as well as a "cross-functional CSR Council" and EHS policies, indicating an internal body with responsibility for overseeing external engagement. The company also describes a concrete review step for at least one piece of direct lobbying, noting that it has "evaluated" its support for the Irish Government Climate Action Plan and confirmed it is "aligned" with the Paris Agreement, which shows some mechanism for checking direct advocacy against climate goals. However, the disclosure reveals little active management of indirect lobbying: for both the National Association of Manufacturers and the U.S. Chamber of Commerce the company records its stance as "Unknown," admits "No, we did not attempt to influence their position," and adds "No, we have not evaluated" alignment with global climate treaties, suggesting that trade-association activity is neither systematically monitored nor corrected. The process description is high-level and does not specify the frequency, criteria, or outcomes of reviews, and no public climate-lobbying audit or board-level sign-off is mentioned. This indicates a moderate level of lobbying governance, with some oversight and direct-alignment checks, but limited transparency and no clear mechanism to manage or align indirect lobbying positions.