Deere & Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Deere & Co outlines a cross-functional mechanism that links climate strategy to external advocacy by stating that it “organized a new Climate Team … comprised of a cross functional team of individuals” from Public Affairs, Legal, Environmental and other functions that “monitors … representative customer trade associations’ positions, climate regulation and legislation globally, and other carbon marketplace news.” The company notes that “the team discusses if the company or any division or facility should be doing anything differently” and “engages throughout the organization to ensure alignment and assess performance toward our goals and targets,” demonstrating a recurring review process aimed at keeping engagement activities consistent with climate objectives. This team therefore provides an identified body that oversees at least some aspect of lobbying alignment. However, the disclosure stops short of describing a formal board-level sign-off, a dedicated climate-lobbying audit, or specific procedures for correcting or exiting misaligned trade associations, and we found no evidence of a public commitment to conduct lobbying “in line with the goals of the Paris Agreement.” The Political Engagement Report focuses mainly on PAC contributions and explicitly states that “JDPAC does not engage in legislative matters or lobbying activity,” offering no additional governance detail for the company’s own direct or indirect lobbying. Overall, Deere & Co shows a limited yet identifiable process for aligning policy engagement with its climate strategy, but it does not provide comprehensive monitoring details, active alignment actions, or higher-level oversight, indicating moderate but incomplete governance of climate-related lobbying. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Deere & Co outlines a cross-functional mechanism that links climate strategy to external advocacy by stating that it “organized a new Climate Team … comprised of a cross functional team of individuals” from Public Affairs, Legal, Environmental and other functions that “monitors … representative customer trade associations’ positions, climate regulation and legislation globally, and other carbon marketplace news.” The company notes that “the team discusses if the company or any division or facility should be doing anything differently” and “engages throughout the organization to ensure alignment and assess performance toward our goals and targets,” demonstrating a recurring review process aimed at keeping engagement activities consistent with climate objectives. This team therefore provides an identified body that oversees at least some aspect of lobbying alignment. However, the disclosure stops short of describing a formal board-level sign-off, a dedicated climate-lobbying audit, or specific procedures for correcting or exiting misaligned trade associations, and we found no evidence of a public commitment to conduct lobbying “in line with the goals of the Paris Agreement.” The Political Engagement Report focuses mainly on PAC contributions and explicitly states that “JDPAC does not engage in legislative matters or lobbying activity,” offering no additional governance detail for the company’s own direct or indirect lobbying. Overall, Deere & Co shows a limited yet identifiable process for aligning policy engagement with its climate strategy, but it does not provide comprehensive monitoring details, active alignment actions, or higher-level oversight, indicating moderate but incomplete governance of climate-related lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Deere & Co provides extensive, concrete detail on every aspect of its climate-policy advocacy. It names numerous measures it has engaged on, including the California Air Resources Board’s Low Carbon Fuel Standard, the Inflation Reduction Act, the federal Renewable Fuel Standard, the U.S. Farm Bill and the Growing Climate Solutions Act, as well as EPA biofuel-blending proposals and related infrastructure policies for wider biofuels use. The company is equally explicit about how and where it lobbies: it “filed multiple comments to the California Air Resources Board,” “submitted comments to the EPA in FY22 and FY23,” “engag[ed] Members of Congress to advocate for more aggressive biofuels blending targets and year-round sales of E15,” and worked with “U.S. regulators” on the design of clean-technology tax credits, clearly identifying CARB, the EPA, Members of Congress, and other U.S. regulators as its targets. Deere also spells out the outcomes it pursues, such as “incorporation of updated emission factors related to crop production to the most recent version of GREET,” inclusion of farm-level GHG accounting in the LCFS, securing eligibility rules so facility investments qualify for new tax credits, having EPA set higher biofuel blending mandates while opposing Small Refiner Exemptions, and promoting policies that incentivize precision-agriculture equipment and feedstock crops. This level of specificity around the policies addressed, the lobbying channels used, and the concrete legislative or regulatory changes sought demonstrates a comprehensive degree of transparency in the company’s climate-related lobbying disclosures.	4