Volkswagen AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	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 Groups 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. Volkswagens 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. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

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 Groups 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. Volkswagens 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.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Volkswagen AG provides a very detailed picture of its climate-policy advocacy. It names numerous concrete legislative files across multiple jurisdictions, including the “European Green Deal,” the “Fit for 55” package, the planned “Euro 7 legislation,” “EU Fleet emission standards,” the extension of the “EU Emissions Trading System to the transport sector,” US “CAFE and GHG regulation,” the German “Klimaschutzgesetz,” and the link between CO₂-fleet targets and infrastructure rules such as “AFIR” and “EPBD.” The company also refers to policy instruments it backs such as “an EU-wide and cross-sectoral CO₂ pricing” and a “CO₂ border adjustment mechanism,” showing it is explicit about which laws it seeks to influence and where. Volkswagen explains how it engages: its Public Affairs teams “coordinate political representation worldwide,” advocacy “mainly takes place through Trade Associations and by direct exchange with responsible Policy makers,” it participates in official consultations, publishes a “CEO alignment letter,” and senior executives have met named officials such as the Spanish Prime Minister and Minister for Industry. The company is registered in both the EU and German lobby registers and “brings its positions into the discussions in the associations,” indicating clear and multiple mechanisms and identifiable targets in the EU, USA and China. Finally, Volkswagen is explicit about the outcomes it pursues, supporting “legally binding expansion targets and charging point quotas for all Member States,” advocating that integrating transport into the EU-ETS would “ensure achievement of the revised EU climate target for 2030 (-55 %),” calling for a “fair CO₂ border adjustment mechanism,” and seeking a “-50 % reduction compared to the 2021 level” for future CO₂-fleet standards while ensuring Euro 7 rules remain “technically feasible.” This combination of specific policies, clearly described engagement channels and well-defined legislative objectives demonstrates a high level of transparency in the company’s climate-related lobbying.	A