DWS Group GmbH & Co KGaA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	DWS discloses only cursory mechanisms that might touch on lobbying alignment and provides no dedicated description of how it governs either its own direct advocacy or its involvement in trade associations. The only concrete process that could relate to indirect lobbying is that, “in 2021, the DWS Group Sustainability Office (GSO) has set up a new approval process for new ESG related initiatives (commitments or memberships) to ensure that such new initiatives are in line with our group-wide sustainability strategy – and specifically our net zero approach.” While this shows that new memberships must be screened for consistency with the company’s climate strategy, DWS does not describe how existing associations are reviewed, how direct policy engagement is monitored, or who is formally accountable for enforcing alignment. The reference that “We expect Investee Companies to be transparent about their lobbying activities” outlines stewardship expectations for portfolio companies, not an internal governance process. Although broader sustainability oversight bodies are detailed – for example, “the Group Sustainability Council supported the Board in driving group-wide alignment and oversight of climate-related activities” – none of the committees’ mandates explicitly cover lobbying governance. No individual or board committee is named as responsible for reviewing lobbying alignment, and there is no mention of a lobbying audit, trade-association review, or disclosure of DWS’s own lobbying expenditures. Consequently, the company provides only limited evidence of a lobbying governance framework and no specific climate-lobbying governance beyond the approval step for new ESG-related memberships. View Sources	D

Overall Assessment

Analysis

Score

Limited

DWS discloses only cursory mechanisms that might touch on lobbying alignment and provides no dedicated description of how it governs either its own direct advocacy or its involvement in trade associations. The only concrete process that could relate to indirect lobbying is that, “in 2021, the DWS Group Sustainability Office (GSO) has set up a new approval process for new ESG related initiatives (commitments or memberships) to ensure that such new initiatives are in line with our group-wide sustainability strategy – and specifically our net zero approach.” While this shows that new memberships must be screened for consistency with the company’s climate strategy, DWS does not describe how existing associations are reviewed, how direct policy engagement is monitored, or who is formally accountable for enforcing alignment. The reference that “We expect Investee Companies to be transparent about their lobbying activities” outlines stewardship expectations for portfolio companies, not an internal governance process. Although broader sustainability oversight bodies are detailed – for example, “the Group Sustainability Council supported the Board in driving group-wide alignment and oversight of climate-related activities” – none of the committees’ mandates explicitly cover lobbying governance. No individual or board committee is named as responsible for reviewing lobbying alignment, and there is no mention of a lobbying audit, trade-association review, or disclosure of DWS’s own lobbying expenditures. Consequently, the company provides only limited evidence of a lobbying governance framework and no specific climate-lobbying governance beyond the approval step for new ESG-related memberships.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	DWS Group offers only limited transparency on its climate-policy lobbying. It does identify two specific pieces of EU legislation—the Energy Performance of Buildings Directive and the Energy Efficiency Directive—and even cites particular provisions such as "Minimum Energy Performance Standards" and the planned "Phase-out date for fossil-fuel boilers by 2040 or earlier," showing that it has at least acknowledged which public measures it has engaged on. However, the company gives little insight into how it tries to influence those rules. Apart from noting that "Yes, we engage indirectly through trade associations" and that it sent "a dedicated engagement letter on net-zero actions to more than 220 companies across different sectors," the disclosure does not spell out meetings, submissions, or other channels directed at identifiable government bodies or lawmakers; most of the described activity is aimed at investee companies rather than policymakers. Likewise, the outcomes DWS seeks remain largely aspirational—such as encouraging companies to adopt net-zero targets or calling for better alignment between energy-efficiency policies and sustainable finance—without setting out the concrete legislative changes, amendments, or quantitative targets it is advocating for. This leaves stakeholders with only a partial picture of the firm’s climate-related lobbying intentions and actions.	D