Amgen Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Amgen has instituted a structured oversight framework for monitoring its climate-related lobbying, exemplified by the dedicated disclosures and targeted reviews of its trade association memberships, yet it does not provide a clear mechanism for aligning its direct lobbying activities with its climate objectives. Specifically, Amgen publishes a section titled “Results of Our Annual Review of U.S. Trade and Industry Associations That Conduct Climate Lobbying and Alignment on Climate Lobbying,” in which “our process and methodology included reviewing our memberships and conducting an assessment of climate-related policy and advocacy positions to determine alignment with the Paris Agreement’s goal of limiting the global average temperature rise to 1.5 degrees Celsius.” The company commits that “if misalignment … is identified in the future, we will consider whether or not to remain a member” and that “we will continue to closely monitor these associations,” demonstrating a proactive approach to governing indirect lobbying. Governance oversight is provided by Amgen’s Board and its Corporate Responsibility and Compliance Committee, which “oversees our government affairs activities, including our political contributions … public policy positions,” and by the Senior Vice President, Global Government Affairs and Policy, leading the Global Government Affairs and Policy team under the committee’s oversight. However, the company states that “While we do not directly lobby for climate change,” and we found no evidence of a defined process to ensure that any direct lobbying is systematically aligned with its climate commitments, suggesting that direct lobbying alignment is not clearly governed. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Amgen has instituted a structured oversight framework for monitoring its climate-related lobbying, exemplified by the dedicated disclosures and targeted reviews of its trade association memberships, yet it does not provide a clear mechanism for aligning its direct lobbying activities with its climate objectives. Specifically, Amgen publishes a section titled “Results of Our Annual Review of U.S. Trade and Industry Associations That Conduct Climate Lobbying and Alignment on Climate Lobbying,” in which “our process and methodology included reviewing our memberships and conducting an assessment of climate-related policy and advocacy positions to determine alignment with the Paris Agreement’s goal of limiting the global average temperature rise to 1.5 degrees Celsius.” The company commits that “if misalignment … is identified in the future, we will consider whether or not to remain a member” and that “we will continue to closely monitor these associations,” demonstrating a proactive approach to governing indirect lobbying. Governance oversight is provided by Amgen’s Board and its Corporate Responsibility and Compliance Committee, which “oversees our government affairs activities, including our political contributions … public policy positions,” and by the Senior Vice President, Global Government Affairs and Policy, leading the Global Government Affairs and Policy team under the committee’s oversight. However, the company states that “While we do not directly lobby for climate change,” and we found no evidence of a defined process to ensure that any direct lobbying is systematically aligned with its climate commitments, suggesting that direct lobbying alignment is not clearly governed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Amgen has provided a moderate level of transparency around its climate lobbying activities. The company details its lobbying mechanisms clearly, including its Global Government Affairs and Policy team’s engagement with elected officials and policymakers at federal and state levels, its quarterly federal lobbying reports, and its annual state-level reports, as well as participation in associations like the Renewable Thermal Collaborative and the Environmental Defense Fund Climate Corp Fellows program. While Amgen discloses its membership in climate-focused initiatives and describes its review of trade association payments and alignment with the Paris Agreement’s 1.5 °C goal, it does not identify specific climate policies or legislation it has lobbied. Moreover, the company expresses broad ambitions such as achieving carbon neutrality in its owned and operated facilities by 2027 without outlining targeted legislative or regulatory changes it aims to influence.	C