Greenbrier Cos Inc/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Greenbrier discloses that “Greenbrier operates a Political Action Committee (PAC) to support its governmental affairs activities,” in which “only a small number of senior managers and directors are eligible to participate and donate.” It also states that “Greenbrier participates in a number of trade associations, industry groups and nonprofits across North America” and that “we strive to ensure any policy differences that Greenbrier may have with these broad member-based organizations are balanced against the productive value of our continued participation in each organization.” The company further explains that “Greenbrier reviews its participation in these organizations as memberships come up for renewal,” indicating a basic review process for its indirect lobbying affiliations. However, it does not disclose any specific individual or formal body responsible for overseeing lobbying, nor does it describe a policy or structured process to align its lobbying activities with its business objectives or any climate-related goals. We found no indication of how direct lobbying is managed or how trade-association engagement is assessed against broader policy commitments. View Sources	D

Overall Assessment

Analysis

Score

Limited

Greenbrier discloses that “Greenbrier operates a Political Action Committee (PAC) to support its governmental affairs activities,” in which “only a small number of senior managers and directors are eligible to participate and donate.” It also states that “Greenbrier participates in a number of trade associations, industry groups and nonprofits across North America” and that “we strive to ensure any policy differences that Greenbrier may have with these broad member-based organizations are balanced against the productive value of our continued participation in each organization.” The company further explains that “Greenbrier reviews its participation in these organizations as memberships come up for renewal,” indicating a basic review process for its indirect lobbying affiliations. However, it does not disclose any specific individual or formal body responsible for overseeing lobbying, nor does it describe a policy or structured process to align its lobbying activities with its business objectives or any climate-related goals. We found no indication of how direct lobbying is managed or how trade-association engagement is assessed against broader policy commitments.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Greenbrier provides only limited insight into its climate-related lobbying. It indicates that it supports freight-rail and marine transportation through a corporate Political Action Committee and that it works through trade associations to develop policy recommendations, but it does not identify which government departments, legislators, or regulatory agencies receive these efforts. The company references broad policy areas—such as the United States-Mexico-Canada Agreement, rail-infrastructure investment, railroad-equipment regulation, and developing a disclosure framework for Scope 3 emissions—yet it does not name any specific bills, regulations, or rulemakings it has sought to influence. Likewise, the outcomes it seeks are described in general terms—promoting free trade, encouraging near-shoring, and shaping a workable Scope 3 reporting framework—without quantifiable targets or detailed legislative changes. Overall, the disclosures acknowledge some lobbying activity but leave most of the critical details unexplained, offering only a limited level of transparency.	D