Linde PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Linde PLC discloses climate-policy lobbying with a high degree of specificity. It names multiple identifiable measures it has worked on, including the U.S. "Tax credit for carbon oxide sequestration (Section 45Q)," the "Bipartisan Infrastructure Law," the "Build Back Better" package of clean-hydrogen and carbon-capture tax credits, the "EU Renewable Energy Directive" (including delegated acts on renewable and low-carbon hydrogen), and the forthcoming "EU taxonomy legislation" and "Hydrogen Decarbonised Gas Market package." The company is equally clear about how it lobbies and whom it targets, describing "meetings, submission of proposals or inquiries," “direct dialogue with political decision-makers in the U.S. (e.g., United States Congress), in Europe (e.g., EU Commission, Member States) and other geographies,” and indirect advocacy through trade bodies such as the Hydrogen Council and the European Industrial Gases Association. Finally, Linde sets out the concrete outcomes it seeks: it “advocated for favorable conditions” under Section 45Q, supports “production and investment tax credits for clean hydrogen,” calls for “regional clean hydrogen hubs,” and has proposed “a more flexible and pragmatic design of the criteria for additionality, temporal and geographical correlation of the electricity used to generate renewable hydrogen” within the EU framework. These detailed explanations of policies, mechanisms and desired legislative changes demonstrate comprehensive transparency around the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Linde maintains a moderate governance process to oversee climate-related lobbying: it “maintains a detailed oversight process to ensure our activities are conducted in a legal, ethical and transparent manner and are consistent across business units and geographies,” with “oversight by the Chief Compliance Officer and an annual program review by the Board of Directors” and its Government Relations department “provides regular reporting on such activities to the Chief Compliance Officer and reports to the General Counsel.” The company further “coordinates with the Vice President Sustainability, and General Counsel to ensure consistency of public policy advocacy with Linde's global sustainability strategy, including our energy and GHG strategy and targets, which are aligned with the Paris Agreement,” and the Vice President Sustainability “works closely with Government Relations and participates in cross-functional groups to review advocacy positions that have an environmental or climate change impact,” while Government Relations holds “a seat on the Sustainable Development Council, which meets quarterly.” These elements demonstrate clear internal monitoring and named oversight for direct lobbying. However, we found no evidence of a process for aligning indirect lobbying through trade or industry associations or any dedicated climate-lobbying audit or public report assessing alignment, indicating that governance of some lobbying channels and comprehensive reviews remains limited.	2