Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]AAM utilizes the same governance structure and processes we developed for our overall sustainability program to ensure that our direct and indirect activities that may influence policy are consistent with our overall strategy regarding climate change. Activities that further the Company's overall climate change strategy are subject to approval of the corporate Policy Committee and/or the CEO. As the Sustainability Program Lead (and a member of this committee), the President is responsible for bringing high-level policy or funding decisions to the Committee. If approved, the President would report significant decisions affecting strategy to the Board of Directors. There were no activities requiring such approval during 2021.
As a Tier 1 automotive supplier, AAM has been a member of well-established industry trade associations for decades. Over time, a number of these associations have developed expertise and taken positions regarding climate change policy that generally support the automotive industry's efforts to address climate change. Notably, the Automotive Industry Action Group (AIAG), the Forging Industry Association (FIA), National Association of Manufacturers (NAM) and the Suppliers Partnership for the Environment (SP) have publicly stated their positions on climate change. As a member of these trade associations, our participation is indirect.
AAM's Code of Business Conduct prohibits the use of Company funds for political purposes, including for contributions to a political party, candidate or committee. Accordingly, we do not maintain a political action committee (PAC). However, we actively monitor the regulatory environment and changes in laws and governmental policies as a matter of importance to our commitment to comply with environmental laws and regulations and reduce the environmental impact of our operations.