ZF Commercial Vehicle Control Systems India Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong ZF Commercial Vehicle Control Systems India Ltd (part of ZF Group) is highly transparent about its climate-policy lobbying activities. It identifies a broad suite of specific measures it works on, naming the “EU Green Deal,” “Revision of CO2 fleet targets for PassCars, LCV and HDV,” “RePower EU,” “Company Car taxation Germany,” the “US plug-in vehicle tax credit,” “EPA GHG Emissions Standards (LD, MD, HD)” and related US fuel-economy standards, demonstrating clarity about the individual laws and regulations it seeks to influence. The company also explains how and where it acts: it is “part of the activities of associations (CLEPA, VDA, MEMA) as well as … industry groups, like the industrial renewable platform in the EU-COM,” and undertakes “direct contacts with MPs, ministries, EU commissioners, and US regulators and legislators.” By describing indirect routes (trade associations, cross-sector platforms, funding bodies) alongside direct engagement with named governmental actors, the disclosure provides a clear picture of both mechanisms and targets. On outcomes, ZF sets out the policy changes it advocates, such as a “revision of CO2 Fleet targets” that is “open for technology and including renewable fuels (E-Fuels) to also decarbonize the existing fleet,” and it states its stance on measures like the US e-mobility tax credits as “Support with minor exceptions.” While these positions are generally framed, they still indicate the direction of change the company is pushing for and the rationale behind it. Taken together, the disclosures give a strong, though not exhaustive, account of the company’s climate-related lobbying intentions and methods. 3
Lobbying Governance
Overall Assessment Comment Score
Limited ZF Commercial Vehicle Control Systems India discloses that it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement,” and states that it has defined processes “to ensure that your engagement activities are consistent with your overall climate change strategy.” However, the description that follows—detailing how the sustainability department “regularly reports into senior management up to the Board of Management,” reviews the materiality matrix, and “coordinates the internal and external communication of sustainability – stakeholder dialogue”—focuses on general sustainability management rather than on the governance of lobbying or policy advocacy. The evidence does not specify mechanisms for monitoring or correcting direct lobbying positions, makes no reference to reviewing the climate-policy stances of trade associations, and does not name an individual or committee expressly responsible for overseeing lobbying alignment. Consequently, while the company publicly commits to align its engagement with the Paris goals, we found no further disclosure of the structures, oversight procedures, or audits that would demonstrate a systematic governance process for climate-lobbying alignment. 1