Volkswagen AG

Volkswagen AG discloses a detailed governance framework that actively manages and monitors both its own lobbying and its participation in trade associations, with a specific focus on climate alignment. The company states that "all areas and roles in the group that carry out tasks of representing political interests inform the Public Affairs Division of their activities" and must "unalteredly advocate the Group's positions in discussions with policy makers and associations"; any breach is "escalat[ed] to the Group Steering Committee for Public Affairs which is directly connected to the Board of Management of the Volkswagen Group," demonstrating a clear process and named oversight body for direct lobbying. For indirect lobbying, Volkswagen has published its first "Volkswagen Group Association Climate Review," explaining that it "review[ed] our association memberships with a view to their alignment with our climate policy positions," and that the Review "will be published regularly," signalling a recurring, public audit of trade-association alignment with climate goals. The methodological approach was "developed in an overarching project group consisting of experts from the Investor Relations, Sustainability and Public Affairs departments" and "the whole project and process is supervised at senior level by the Heads of Group Treasury and Investor Relations, Sustainability and Group Public Affairs," providing additional accountability. Associations classified as "partly aligned or misaligned" are brought to "Panel meetings" where "a strategy to ensure future alignment is developed" and decisions are taken on how to proceed, evidencing an active mechanism to correct misalignment. Volkswagen's overarching "Political One-Voice Policy... only permit[s] lobbying to be carried out through designated channels with defined Principles and Guidelines for Public Affairs" and assigns responsibility to "the Group Public Affairs office or the Group Steering Committee Public Affairs," ensuring direct and indirect activities follow the same climate-aligned positions. Finally, the company publicly commits to conduct engagement "in line with the goals of the Paris Agreement." Together, the publicly available climate-lobbying review report, the structured alignment processes, and board-linked oversight indicate a comprehensive and transparent lobbying governance system.