Spirit AeroSystems Holdings Inc

Spirit AeroSystems describes a clear process for aligning its indirect lobbying through trade associations with its climate strategy, stating that "prior to entering into new affiliations or expanding the scope of current affiliations, an organization's policy positions are among the several factors that we would consider," that through "membership and participation, we would be able to monitor whether their activities are consistent with our climate and energy strategy," and that the company "utilizes our disclosures to the CDP Climate Change program as an opportunity to further review and assess whether the public policy positions of trade associations for which Spirit AeroSystems has an affiliation are consistent with our own climate change strategy." While these steps represent a concrete mechanism for monitoring and aligning indirect engagement, the company does not disclose how it governs or aligns its direct lobbying activities nor does it identify any individual or formal body responsible for overseeing lobbying alignment.