Covestro AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Covestro discloses a structured process to keep its policy engagement in line with its climate ambitions. It states that “Covestro ensures that its advocacy is aligned with its own climate targets and the goals of the Paris Agreement through management processes that ensure that employees who directly represent interests for Covestro as well as employees who represent Covestro in industry associations are briefed and aware of Covestro’s positions on energy and climate policies,” showing that both direct lobbyists and those active in trade associations are brought under the same alignment framework. Oversight is clearly assigned: the Supervisory Board’s Sustainability Committee “supports, monitors, and issues recommendations on the Board of Management’s ESG strategies, targets, and initiatives,” while at executive level “the newly created corporate function of Sustainability & Public Affairs is headed by Covestro’s Chief Sustainability Officer; it ensures alignment between Covestro’s sustainability goals and its advocacy,” and the CEO chairs the ESG Governance Body that reviews positions and outreach. The company also describes day-to-day management mechanisms: “Caretakers for industry associations are responsible for coordinating the activities of employees tasked with representing Covestro’s interests in these industry associations,” and employees are kept updated “in Townhall Meetings to ensure knowledge transfer and information dissemination in a timely manner.” These disclosures indicate strong internal governance that covers both direct and indirect lobbying, names accountable bodies and individuals, and embeds regular review and communication steps. However, the evidence does not mention a publicly available climate-lobbying alignment report or an external audit, nor does it describe criteria for challenging or exiting misaligned associations, so the transparency and external assurance of the process remain limited. View Sources	B

Overall Assessment

Analysis

Score

Strong

Covestro discloses a structured process to keep its policy engagement in line with its climate ambitions. It states that “Covestro ensures that its advocacy is aligned with its own climate targets and the goals of the Paris Agreement through management processes that ensure that employees who directly represent interests for Covestro as well as employees who represent Covestro in industry associations are briefed and aware of Covestro’s positions on energy and climate policies,” showing that both direct lobbyists and those active in trade associations are brought under the same alignment framework. Oversight is clearly assigned: the Supervisory Board’s Sustainability Committee “supports, monitors, and issues recommendations on the Board of Management’s ESG strategies, targets, and initiatives,” while at executive level “the newly created corporate function of Sustainability & Public Affairs is headed by Covestro’s Chief Sustainability Officer; it ensures alignment between Covestro’s sustainability goals and its advocacy,” and the CEO chairs the ESG Governance Body that reviews positions and outreach. The company also describes day-to-day management mechanisms: “Caretakers for industry associations are responsible for coordinating the activities of employees tasked with representing Covestro’s interests in these industry associations,” and employees are kept updated “in Townhall Meetings to ensure knowledge transfer and information dissemination in a timely manner.” These disclosures indicate strong internal governance that covers both direct and indirect lobbying, names accountable bodies and individuals, and embeds regular review and communication steps. However, the evidence does not mention a publicly available climate-lobbying alignment report or an external audit, nor does it describe criteria for challenging or exiting misaligned associations, so the transparency and external assurance of the process remain limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Covestro provides extensive, detailed disclosure of its climate-related lobbying. It names several distinct policy dossiers it seeks to influence, including the European “Emissions Trading Scheme,” German government initiatives such as “Wirtschaft macht Klimaschutz,” the national and EU roll-out of hydrogen technologies, and European energy-efficiency legislation aimed at raising the building-renovation rate. The company also spells out an array of direct and indirect channels it uses: its representatives “actively contributed in the following committees: – Council of economic advisors of the German Christian Democrats (CDU) party [and] Economic dialog of the German Green party,” it notes that “Covestro representatives are members of the economic advisory council of the German Green party” and that its CTO sits on the German National Hydrogen Council; it further lists “responding to consultations, meeting with policy makers, actively working with trade associations, and participating in workshops and panel debates,” and cites individual engagements with EU figures such as Pascal Canfin and Kadri Simson as well as members of the U.S. Congress. Finally, Covestro is explicit about what it wants policy makers to do: it seeks revisions to the “carbon leakage list,” the inclusion of “CCU/S and waste incineration” in the ETS scope, a “more effective and legally certain framework at EU level” for electrification and hydrogen use, and advocates “to push for an increase renovation rate in Europe.” By clearly identifying the policies, the forums and targets of its lobbying, and the precise outcomes it aims to achieve, the company demonstrates a comprehensive level of transparency on its climate-policy advocacy.	A