Steelcase Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Steelcase discloses a structured governance process that explicitly links its climate-related advocacy to its corporate climate goals. It states that "our government affairs are primarily managed by the Assistant General Counsel, who manages and coordinates all policy-related engagements, including those related to climate change and sustainability,” establishing a clear point of accountability for lobbying activities. Day-to-day alignment work is further embedded as “the Manager of Carbon Strategy…works closely with the Assistant General Counsel to identify opportunities to engage with trade associations… and directly with policymakers… ensuring that all engagements are consistent with our climate commitments and with a 1.5°C-aligned future.” Before positions are taken externally, “approval for any public positions or actions… is typically sought from the Director of Sustainability, and when necessary, from the SVP, Chief Administrative Officer, General Counsel and Secretary,” while “the Assistant General Counsel also reviews any proposed public positions or actions to ensure they align with the greater corporate government affairs strategy and do not expose us to unforeseen or undue risks.” This chain of review covers both direct lobbying and indirect engagement through trade associations and gives named individuals clear oversight duties, indicating strong governance. The company also references broader board-level oversight as “The Nominating and Corporate Governance Committee of the Steelcase Board of Directors oversees the company’s strategy and policies concerning Environmental, Social, and Governance (ESG) matters.” However, Steelcase does not disclose a formal, publicly available lobbying-alignment audit or a detailed mechanism for systematically assessing the climate positions of each trade association, so the extent of monitoring beyond internal approvals remains unclear. View Sources	3

Overall Assessment

Analysis

Score

Strong

Steelcase discloses a structured governance process that explicitly links its climate-related advocacy to its corporate climate goals. It states that "our government affairs are primarily managed by the Assistant General Counsel, who manages and coordinates all policy-related engagements, including those related to climate change and sustainability,” establishing a clear point of accountability for lobbying activities. Day-to-day alignment work is further embedded as “the Manager of Carbon Strategy…works closely with the Assistant General Counsel to identify opportunities to engage with trade associations… and directly with policymakers… ensuring that all engagements are consistent with our climate commitments and with a 1.5°C-aligned future.” Before positions are taken externally, “approval for any public positions or actions… is typically sought from the Director of Sustainability, and when necessary, from the SVP, Chief Administrative Officer, General Counsel and Secretary,” while “the Assistant General Counsel also reviews any proposed public positions or actions to ensure they align with the greater corporate government affairs strategy and do not expose us to unforeseen or undue risks.” This chain of review covers both direct lobbying and indirect engagement through trade associations and gives named individuals clear oversight duties, indicating strong governance. The company also references broader board-level oversight as “The Nominating and Corporate Governance Committee of the Steelcase Board of Directors oversees the company’s strategy and policies concerning Environmental, Social, and Governance (ESG) matters.” However, Steelcase does not disclose a formal, publicly available lobbying-alignment audit or a detailed mechanism for systematically assessing the climate positions of each trade association, so the extent of monitoring beyond internal approvals remains unclear.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Steelcase demonstrates a moderate level of transparency around its climate lobbying. The company details its engagement through trade associations such as the Business Roundtable and Clean Energy Buyers Association, chairs the Grand Rapids Chamber’s Infrastructure and Natural Resources Committee, and submitted formal comments to the U.S. Securities and Exchange Commission on its proposed climate-related disclosure rule. In contrast, Steelcase names only one specific policy engagement—the SEC’s proposed rule on enhancing and standardizing climate-related disclosures—otherwise describing its advocacy in broad strokes as support for a science-based, net-zero agenda aligned with the Paris Agreement. At the same time, Steelcase clearly outlines the outcomes it seeks, including expanding organized wholesale electricity markets to unlock more affordable and cleaner resources, increasing renewable energy capacity and competition in Michigan, and supporting an at least 80% reduction in U.S. greenhouse gas emissions by 2050 in line with a 1.5°C policy pathway.	2