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Autoneum Holding AG has established multiple governance bodies for sustainability and compliance, such as the “Corporate Responsibility Steering Committee” which “monitors the implementation of the sustainability strategy and continuously reviews potential risks in the area of Corporate Responsibility,” and the “Strategy and Sustainability Committee” which supports the Board on topics “including sustainable processes, products, technologies, supply chain management, environmental risks and the reduction of greenhouse gas emissions.” The evidence also details that “The Board of Directors ... defines and adopts the Group’s compliance strategy and addresses key compliance risks” and that the Group Legal & Compliance department “ensures the implementation and continuous improvement of the Compliance Program.” However, we found no evidence of any governance process specifically for lobbying or of any oversight mechanism—internal reviews, committees, named roles, or monitoring procedures—dedicated to aligning the company’s direct or indirect lobbying activities with its stated climate or policy objectives.
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