Caterpillar Inc

Caterpillar appears to have implemented a moderate governance framework for climate lobbying. The company publishes an annual Lobbying Report which "provides greater transparency and disclosure of our advocacy efforts and political engagements, including climate lobbying, as well as a description of the oversight and management of these activities." This report outlines measures "designed to ensure that any payments of trade association dues and corporate political contributions are processed in compliance with our political spending policies and tracked to support our disclosures in the Lobbying Report," alongside enhancements in reporting thresholds of trade and industry association memberships. Sustainability oversight is conducted at the highest levels, with the board's newly formed Sustainability and other Public Policy Committee (SPPC) that "has oversight of climate and sustainability" and oversight also extending to the CEO and Chief Sustainability Officer. However, we found no evidence of a dedicated policy or process to explicitly align either direct or indirect lobbying activities with the company's climate policy positions, such as board sign-off on climate-advocacy plans or criteria for evaluating the climate alignment of trade associations.