CNH Industrial NV

CNH Industrial NV has established a governance framework for ensuring its policy engagement aligns with its climate commitments by relying on its Code of Conduct and related policies and procedures. As the company states, "CNHI uses the Code of Conduct, its policies, and related procedures to ensure a consistent Company-wide approach in line with its climate change strategy, and regulate CNHI's relationships with various types of public and private organizations," and this framework extends to both its direct advocacy through its Institutional Relations functions and its indirect engagement as a member of industry associations. Oversight of these activities is clearly assigned, with "the highest responsibility for CNHI's Institutional Relations" resting with the Senior Leadership Team (SLT), while each geographic unit is responsible for "monitoring policy trends and engaging with public authorities, trade associations, international organizations, business sector, and NGOs in the institutional and regulatory decision-making processes." CNH further demonstrates alignment of its indirect lobbying priorities by participating in bodies such as ACEA and Hydrogen Europe that "support the public debate and legislation to foster the clean energy transition and the future zero-emission mobility." However, the company does not disclose any dedicated procedures or review processes - such as a climate-lobbying audit, explicit sign-off mechanisms, or criteria for reassessing associations - to systematically evaluate and manage the alignment of its lobbying positions.