Johnson Controls International plc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Johnson Controls discloses a well-defined structure that integrates climate policy oversight with its lobbying activities. It states that "our lobbying and political activities are overseen by our Chief Sustainability & External Relations Officer, who works closely with our legal department" and that this officer "reports to the Governance and Sustainability Committee on our governmental outreach, PAC and other political activities on a quarterly basis, and the full Board is briefed ... at least annually," demonstrating a named executive and a board committee with a recurring review cadence. The company also explains that "our Sustainability and Government Relations teams are part of the same organization" and that an "ESG, Policy, and Regulatory Leadership Committee… ensures consistency on both our policy advocacy and sustainability activities across the organization," outlining an internal mechanism that links policy engagement to climate strategy. To show the process reaches indirect lobbying, the firm notes that "we use annual governmental affairs meetings… to ensure that our direct and indirect activities that influence policy are consistent with our overall climate change strategy" and highlights examples of influencing associations, such as the CEO’s role in steering the Business Roundtable to "support SEC action on climate change" and holding "key leadership positions in our sector-specific trade associations… to advance net zero buildings." These disclosures indicate active efforts to align both direct and trade-association lobbying with the company’s climate goals. However, the company does not disclose a formal, published lobbying-alignment audit or criteria for assessing and, if necessary, exiting misaligned associations, so the transparency of its monitoring process remains limited. View Sources	3

Overall Assessment

Analysis

Score

Strong

Johnson Controls discloses a well-defined structure that integrates climate policy oversight with its lobbying activities. It states that "our lobbying and political activities are overseen by our Chief Sustainability & External Relations Officer, who works closely with our legal department" and that this officer "reports to the Governance and Sustainability Committee on our governmental outreach, PAC and other political activities on a quarterly basis, and the full Board is briefed ... at least annually," demonstrating a named executive and a board committee with a recurring review cadence. The company also explains that "our Sustainability and Government Relations teams are part of the same organization" and that an "ESG, Policy, and Regulatory Leadership Committee… ensures consistency on both our policy advocacy and sustainability activities across the organization," outlining an internal mechanism that links policy engagement to climate strategy. To show the process reaches indirect lobbying, the firm notes that "we use annual governmental affairs meetings… to ensure that our direct and indirect activities that influence policy are consistent with our overall climate change strategy" and highlights examples of influencing associations, such as the CEO’s role in steering the Business Roundtable to "support SEC action on climate change" and holding "key leadership positions in our sector-specific trade associations… to advance net zero buildings." These disclosures indicate active efforts to align both direct and trade-association lobbying with the company’s climate goals. However, the company does not disclose a formal, published lobbying-alignment audit or criteria for assessing and, if necessary, exiting misaligned associations, so the transparency of its monitoring process remains limited.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Johnson Controls International plc discloses a wide-ranging and granular picture of its climate-policy advocacy, demonstrating a high level of transparency. The company names numerous specific measures it has worked on, including the U.S. Inflation Reduction Act, the American Innovation and Manufacturing Act, ratification of the Kigali Amendment, SEC climate-risk disclosure rules, extension of the Section 48 renewable-energy tax credit, the European Green Deal, the EU Energy Performance of Buildings and Energy Efficiency Directives, and revision of the European F-Gas Regulation, as well as renewable-energy and green-taxonomy initiatives in Mexico, Chile and Colombia. It also explains how it engages: petitioning the U.S. EPA for new HFC rules, submitting comments to the Department of Energy, testifying before the U.S. Senate Budget Committee, meeting President Biden at the White House, “engag[ing] directly” with the SEC, holding a seat on Wisconsin’s Governor’s Task Force on Climate, and working through trade bodies such as the Business Roundtable, EPEE, AHRI and ARAP to reach the EU Commission, Parliament and Council. Finally, Johnson Controls is explicit about the results it is pursuing, such as “support[ing] federal funding of climate-related activities, research and mitigation,” phasing down HFCs globally by 2033, securing incentives in the Inflation Reduction Act to accelerate heat-pump adoption, advancing Binding EU-level energy-efficiency targets, maintaining climate language in U.S. appropriations bills, and promoting building-performance standards that align with net-zero goals. By clearly linking each policy engagement to concrete mechanisms and well-defined legislative or regulatory objectives, the company provides comprehensive insight into its climate lobbying activities.	4