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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Volkswagen AG has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names specific climate policies it has engaged with, such as the "European Green Deal," "Fit for 55" package, "EU Fleet emission standards," "Alternative Fuels Infrastructure Regulation," "Energy Performance of Buildings directive," "Battery Regulation," and "Euro 7 legislation." It also highlights its advocacy for "an EU-wide and cross-sectoral CO2 pricing" and a "CO2 border adjustment mechanism," providing clear details about the policies and jurisdictions involved. Volkswagen describes its lobbying mechanisms in detail, including engagement through trade associations, direct exchanges with policymakers, and participation in initiatives like the "CEO Alliance for Europe's Recovery, Reform and Resilience." The company also adheres to "binding Governance rules" and is registered in the "Transparency Register of the European Union" and the "German lobby register," ensuring compliance and oversight. Furthermore, Volkswagen has been explicit about the policy outcomes it seeks, such as "legally binding expansion targets and charging point quotas for all Member States," adjustments to the "Euro 7 legislation" to ensure technical feasibility, and the extension of the EU emissions trading system to the transport sector to meet EU climate goals. These disclosures reflect a clear articulation of desired policy changes and outcomes, demonstrating a high level of transparency in its lobbying efforts.
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4
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Volkswagen Group demonstrates a comprehensive governance process for climate lobbying alignment, as evidenced by its "Volkswagen Group Association Climate Review." This report is the result of a collaborative effort involving the Investor Relations, Sustainability, and Public Affairs departments, and is supervised at a senior level by the Heads of Group Treasury, Investor Relations, Sustainability, and Group Public Affairs. The governance process includes a "methodological concept" and "selection criteria" for evaluating industry associations, ensuring alignment with Volkswagen's climate commitments and global climate policy positions. The report explicitly states that "the methodological concept, the selection criteria and the analysis of the associations were developed in an overarching project group" and that "the whole project and process is supervised at senior level." Volkswagen has implemented a structured approach to assess alignment, categorizing associations as "aligned," "partly aligned," or "misaligned" based on their public support for key climate policies such as the Paris Agreement and net carbon-neutral vehicles. The company has also outlined a process for addressing partial alignment or misalignment, stating that "a panel (the 'Panel') has been installed under the direction of and chaired by Group Treasury and Investor Relations" to review and address associations identified as partly aligned or misaligned. This panel evaluates results, explores consequences, and develops strategies to ensure future alignment, with withdrawal from associations considered as a last resort. Additionally, Volkswagen has committed to publishing the Review Report regularly, indicating ongoing monitoring and accountability. The report also highlights the company's engagement in dialog with associations to promote alignment, stating, "Volkswagen is of the opinion that only those who are present can effect change," emphasizing the importance of active participation and advocacy. The governance process encompasses both direct and indirect lobbying activities, as the review evaluates industry associations' positions on climate policies and their alignment with Volkswagen's own climate commitments. This indicates a robust governance framework that includes clear monitoring mechanisms, accountability structures, and a commitment to transparency and continuous improvement.
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4
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