CAE Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	CAE discloses several governance mechanisms that indicate a structured, though still partial, approach to overseeing lobbying and its intersection with climate strategy. The company states that "any political or other public policy activity in which CAE engages, including political expenditures, must comply with our Lobbying and Political Contributions Policy and the Anti-Corruption Policy," and the Board’s Governance Committee is mandated to "approve and periodically review (every third year, unless required sooner) CAE’s … Lobbying and Political Contributions Policy" and to "review annually the donations, sponsorships and research projects supported by CAE, with a breakdown by sector, region and spend." This demonstrates a standing policy accompanied by recurring oversight of political engagement and spending. CAE also links lobbying oversight to its broader climate governance, noting that "The Board of Directors has oversight of, and the Executive Management Committee (EMC) has responsibility for, climate-related issues and ensures that the processes in place to ensure that the engagement activities are consistent with the overall climate change strategy," which signals an intention to align external engagement—including lobbying—with climate objectives. However, the disclosure does not describe how direct lobbying positions are reviewed for climate consistency, nor does it provide any detail on monitoring or addressing the positions of trade associations; likewise, no public alignment report or evidence of correcting or exiting misaligned associations is provided. Consequently, while the presence of a formal policy, named board-level oversight and an explicit link to climate-strategy alignment indicates moderate governance strength, the absence of detailed monitoring procedures or evidence of active alignment actions limits the overall robustness of CAE’s lobbying governance framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

CAE discloses several governance mechanisms that indicate a structured, though still partial, approach to overseeing lobbying and its intersection with climate strategy. The company states that "any political or other public policy activity in which CAE engages, including political expenditures, must comply with our Lobbying and Political Contributions Policy and the Anti-Corruption Policy," and the Board’s Governance Committee is mandated to "approve and periodically review (every third year, unless required sooner) CAE’s … Lobbying and Political Contributions Policy" and to "review annually the donations, sponsorships and research projects supported by CAE, with a breakdown by sector, region and spend." This demonstrates a standing policy accompanied by recurring oversight of political engagement and spending. CAE also links lobbying oversight to its broader climate governance, noting that "The Board of Directors has oversight of, and the Executive Management Committee (EMC) has responsibility for, climate-related issues and ensures that the processes in place to ensure that the engagement activities are consistent with the overall climate change strategy," which signals an intention to align external engagement—including lobbying—with climate objectives. However, the disclosure does not describe how direct lobbying positions are reviewed for climate consistency, nor does it provide any detail on monitoring or addressing the positions of trade associations; likewise, no public alignment report or evidence of correcting or exiting misaligned associations is provided. Consequently, while the presence of a formal policy, named board-level oversight and an explicit link to climate-strategy alignment indicates moderate governance strength, the absence of detailed monitoring procedures or evidence of active alignment actions limits the overall robustness of CAE’s lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	CAE Inc offers a moderate level of transparency around its climate-policy lobbying. It identifies the broad areas it works on—energy-efficiency measures in military flight training and climate-risk disclosure standards such as TCFD and the GHG Protocol—but it does not tie these activities to any named piece of legislation or regulation. The company does describe how it engages, noting “discussion with Federal government as the customer, with air force and with provincial governments,” which makes clear that direct meetings are its main channel and that the Canadian federal and provincial authorities and the air force are its principal targets, yet it provides no additional detail on other methods such as written submissions or coalition activity. CAE is most explicit about what it is trying to achieve: it seeks to “increase the percentage of simulation-based training for air force pilots in Canada thereby reducing greenhouse gases vs training in live aircraft,” and it supports the adoption of the TCFD framework, mandatory reporting of Scope 1 and Scope 2 emissions (with Scope 3 to follow), the use of the GHG Protocol, and voluntary rather than mandatory audits of climate disclosures. These clearly articulated objectives, alongside the limited but concrete description of engagement channels and targets, give stakeholders a reasonable—though not comprehensive—picture of the company’s climate-related lobbying efforts.	C