Thyssenkrupp AG

Thyssenkrupp AG demonstrates some governance around climate-related lobbying at the Business Unit level, notably through TK Elevator's approach of communicating "our Science Based Targets" "top-down to the Business Units," where each BU assigns "a BU Coordinator who monitors the progress of our climate targets and KPIs, and coordinates all engagement initiatives and other local activities in line with the global targets," which it says ensures "all our engagement activities are consistent with our overall climate change strategy." This structure covers both direct lobbying - illustrated by engagement with the European Commission on the Ecodesign Directive - and indirect activity "through trade associations" under the coordination of the BU Coordinator. The company also makes a public "commitment to the international targets of the Paris Climate Agreement," affirming that "our direct and indirect engagement is consistently in line with our commitment to the Paris Climate Agreement." However, we found no evidence of a dedicated climate-lobbying audit or report, no disclosure of a specific board committee or named senior executive responsible for overseeing climate lobbying alignment, and the group's "political business interest representation" guidelines focusing on "promote transparency" and legal compliance do not specify processes to monitor or enforce alignment of its lobbying activities with its climate objectives across the broader organization.