Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Limited |
Gentherm provides only minimal disclosure around how it governs lobbying and trade-association activity. The company states that "all charitable donations or similar activities must be approved by the Chief Executive Officer, and in agreement with the Chief Financial Officer, the Chief Human Resources Officer, and General Counsel," indicating that at least some policy-influencing expenditures pass through a senior-level sign-off process. For trade-association memberships the disclosure notes that, when an employee proposes joining a body, "the leader of the department with the anticipated budget responsibility… would make an evaluation on his or her own as to whether or not the group has values which are in relative alignment with Gentherm's," adding that ESG is considered a "core principle of Gentherm" and that the leader "can be relied upon to either approve or deny organizational membership." This shows a rudimentary check for alignment with corporate values and names a responsible decision-maker, which indicates some, albeit informal, oversight. However, the company also concedes that "Gentherm does not currently have any specific processes in place to ensure MEMA/OESA has policies that are consistent with Gentherm's strategic direction on climate change" and that it "does not have a formal process in place to vet the climate position of the organizations we join." It further confirms that there is "No" public commitment to align external engagement with the Paris Agreement. The absence of a documented review framework, of any monitoring or reporting on the lobbying positions of its associations, and of defined board-level or executive-committee oversight means the governance structure for climate-related lobbying remains largely undeveloped.
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D |