Siemens AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Siemens AG provides a very detailed account of its climate-related lobbying. The company names a wide range of identifiable measures it has worked on, including the Energy Efficiency Directive, Renewable Energy Directive, Energy Performance of Buildings Directive, EU Carbon Border Adjustment Mechanism, Alternative Fuels Infrastructure Regulation, EU F-Gas Regulation, EU Taxonomy, the German Energieeffizienzgesetz, the U.S. National Electric Vehicle Infrastructure Formula Program and the Inflation Reduction Act, among many others, demonstrating full transparency on the specific policies it seeks to influence. It also explains how it lobbies and who it targets: disclosures reference “meetings with EU decision-makers, including European Commission, European Parliament and Member States”, “several meetings with members of congress and the administration”, “participation in round tables at BMWI”, submission of position papers, responses to consultations, joint industry letters, high-level events such as the “ERT Green Deal Event with Frans Timmermans”, and ongoing engagement through trade associations and ad-hoc coalitions. Finally, Siemens is explicit about the outcomes it pursues, for example calling for “increasing energy efficiency targets” in the EED, seeking “no cap for renewable energy” and lower charges for green hydrogen in the EEG, pressing for CBAM rules that “avoid undue administrative burdens” while ensuring WTO compliance, advocating that AFIR cover electric catenary systems for trucks, and urging “an early review of the regulation, covering SF6” in the F-gas file. The combination of numerous specific policies, clearly described mechanisms and named targets, and multiple detailed policy positions illustrates a high level of transparency across all aspects of the company’s climate-policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Siemens AG describes a structured internal process to align its lobbying with its climate strategy, noting that "the Managing Board has tasked the Government Affairs Department with performing the necessary coordination duties and has given it the powers it needs" and that the GA department "collaborates closely with the Business Units" through "regularly established calls/exchanges" and "topic-dedicated workshops" to align messaging and positioning on climate-related regulations. This approach ensures that all "policy advocacy activities relating to political leaders, policy-making institutions and authorities" are "consistent with our strategy" and coordinated with the Sustainability Office. However, the company does not disclose a specific individual by name who oversees lobbying alignment, nor does it provide any committee-level oversight beyond the Government Affairs Department. We found no evidence of a published review or audit of its direct or indirect lobbying activities nor any process for assessing the climate positions of trade or industry associations in which it participates.	2