A O Smith Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	A. O. Smith offers only a modest level of transparency about its climate-policy lobbying. It explains that it "actively meets with policy makers and staff independently or via its trade and member associations" and also "hosts policymakers and staff at its facilities to learn more about its products,” providing at least two clear mechanisms and identifying the jurisdictions involved (Europe, Canada and the United States), which shows some clarity on how and where it seeks to influence policy. However, when describing the substance of its engagement it refers only generally to regulations that affect “low or zero-carbon emitting products like condensing gas-fired and heat-pump water-heating equipment” and to the broader theme of the “circular economy,” without naming any specific bills, directives or rulemakings, so readers cannot see precisely which policies were lobbied. On desired outcomes the company discloses a single concrete ask – “a limited set of exceptions for certain commercial water-heating applications” in critical facilities such as hospitals – but otherwise speaks in broad terms about collaborating on “proposed policy solutions that have positive outcomes for the company as well as the broader economy and environment,” leaving most of its policy objectives undefined. Together, these gaps mean the company provides only limited insight into the exact policies it targets and the results it is seeking.	1

Lobbying Governance

Overall Assessment	Comment	Score
None	A O Smith Corp states that “Our company is an active participant in a number of trade associations that help advance our business goals and objectives in the governmental and regulatory arena” and that it “continues to hold board and leadership positions in the following associations: The National Association of Manufacturers, the Water Quality Association and the Air-Conditioning, Heating, and Refrigeration Institute,” but the company does not disclose any internal policy or process to govern or monitor these activities, and we found no evidence of a named individual or formal body responsible for reviewing lobbying alignment with climate policy. The company also confirms that it has “no public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and that “we do not plan to have one in the next two years,” which indicates the absence of a mechanism to align its lobbying with Paris-aligned climate objectives. We found no evidence of any review or audit procedures, criteria for assessing association membership against climate goals, or exit strategies when positions conflict with the company’s climate stance.	0