Voestalpine AG

Voestalpine discloses several elements that indicate a structured, though still partial, approach to governing its climate-related lobbying. It has introduced a dedicated "Lobbying Code of Conduct" that "regulates dealings with stakeholders in Austria as well as in Europe and internationally" and applies to "all members of the management boards, the managing directors, and the non-executive employees", with the additional requirement that "care must be taken to ensure in cases where voestalpine's lobbying activities are supported by third parties that the latter commit to compliance with the Lobbying Code of Conduct." For climate matters, the company explains that "voestalpine group's environmental and climate change activities are coordinated by the department Group Environment ... [and] the results are constantly reported and approved by voestalpine's board," while "the head of the department for strategic environmental management meets regularly with members of voestalpine's board in order to ensure a consistent climate change strategy over all group companies." These statements show a defined process and identify the Board as the approving body, suggesting oversight of how engagement activities, including lobbying, align with climate strategy. The company also confirms a "public commitment ... to conduct [its] engagement activities in line with the goals of the Paris Agreement," signalling an intention to align advocacy with climate goals. However, the disclosures do not describe any systematic review or audit of how its direct lobbying and its participation in "bodies serving advocacy groups, trade associations, and lobbying campaigns" are assessed for climate alignment, nor do they provide examples of modifying or ending memberships where misalignment is found. The absence of publicly available assessments or detailed monitoring criteria limits transparency into the effectiveness of the governance framework.