Ford Motor Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Ford Motor Company provides a highly detailed picture of its climate-policy advocacy. The company names numerous specific measures it has worked on, including the EU Regulation on Alternative Fuels Infrastructure (AFIR), the CO2 Fleet Regulation (EU 2019/631 and its 2023 amendment), Euro 7 emissions rules, the F-Gas Regulation EU 517/2014 and its UK equivalent, the U.S. EPA and NHTSA light- and heavy-duty GHG and CAFE standards, California’s voluntary GHG framework and waiver decision, the UK Electric Vehicle Infrastructure Strategy, and U.N. ECE life-cycle-assessment guidelines, among others. Ford also makes the channels of influence clear. It describes direct meetings with “NHTSA and EPA in the development of fuel economy and GHG standards,” open letters to European Commissioners and MEPs backing a 100 % internal-combustion-engine ban by 2035, a legal “motion to intervene on the side of the EPA” in support of California’s authority, participation in the Heavy-Duty Leadership Group pressuring EPA on Phase 3 truck standards, a petition signed with 27 organisations to EU decision-makers on charging infrastructure, and a letter to U.S. Energy Secretary Jennifer Granholm urging clean-aluminium investment. These disclosures are supplemented by references to ongoing outreach through trade bodies such as the Alliance for Automotive Innovation, the Climate Leadership Council and CEO Climate Dialogue, and by state-level involvement, e.g. “a governor’s focus group developing and supporting energy-efficiency programs in Michigan.” The company is equally explicit about what it wants to achieve. It supports a “100 % CO2 reduction target by 2035” for cars and vans in the EU, “more ambitious targets concerning the uptake of charging infrastructure,” finalisation of EPA Phase 3 heavy-duty GHG rules without delay or weakening, deployment of a vehicle life-cycle-assessment methodology, implementation and optimisation of the post-Brexit F-Gas scheme, and U.S. federal investment “in American-made clean aluminum” using Inflation Reduction Act funds. It further advocates market-based carbon pricing, consumer EV incentives, and a carbon-neutral electricity grid, all framed as aligned with the Paris Agreement. By naming concrete policies, disclosing specific engagement tools and targets, and spelling out the legislative or regulatory outcomes it seeks, Ford demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Ford discloses several mechanisms that indicate a structured, though not yet comprehensive, approach to governing how its lobbying aligns with its climate strategy. The company states that it has "expanded this years 2020 Political Engagement Report to include how we evaluate positions on climate change for the major associations in which we participate, how their positions align with ours and areas where we have taken independent action" and commits that "We will conduct an internal audit of associations lobbying positions and our responses annually. The results of the audit will be reviewed with our leadership." This demonstrates a defined process for monitoring and, where necessary, correcting indirect (trade-association) lobbying. Ford in its 2023 U.S. Political Enaggement Report details its trade associations climate positions and "where we align". However, the description of the trade associations lobbying position is sparse on actual lobbying policy details. Further does Ford describe any process or actions where it identifies misaligns. Oversight responsibility is clearly assigned: "Fords Chief Government Affairs Officer has final authority over501(c)(6) association memberships Support for ballot initiative spending requires approval of the Chief Executive Officer" and "The Nominating and Governance Committee of Fords Board of Directors annually reviews contributions and membership decisions" while the Boards Sustainability, Innovation and Policy Committee "is responsible for reviewing and advising Ford's pursuit of innovative policies and technologies that promote environmental and social sustainability." These disclosures show that senior management and two Board-level committees review lobbying activity. The company also articulates guiding principles for all advocacy "Ford advocates for positions that are science-, market- and performance-based, environmentally sustainable and harmonized" signalling an intention to align direct lobbying with its climate commitments. We found no detail on how Ford systematically monitors or audits its own direct lobbying activities, nor evidence of a publicly available, detailed climate-lobbying alignment report. Accordingly, while the company shows some governance of indirect lobbying and names accountable bodies, the transparency and monitoring of direct lobbying alignment remain limited.	2