Eaton Corp PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Eaton provides a highly detailed picture of its climate-related lobbying. It names a broad suite of specific measures it works on, including the EU “Electricity Market Design reform”, the “revised Renewable Energy Directive (REDIII)”, the “Energy Efficiency Directive”, Euro 7/VII CO2 and NOx standards, the U.S. Inflation Reduction Act tax credits for “Commercial clean vehicles (Sec. 45W)” and “Alternative Fueling Infrastructure (30C)”, new heavy-duty vehicle emission standards in the United States, state adoption of NEC 2020/iCodes, and the phase-out of SF6 switchgear, amongst others. The company is equally explicit about how it seeks to influence these files, stating that it lobbies through “personal contact by employees, contact by lobbyists under contract to Eaton, and by trade associations of which Eaton is a member”, participates in state government working groups, commissions studies for policymakers, and undertakes advocacy in Brussels; it also identifies concrete targets such as the “U.S. National Highway Transportation Safety Administration”, state and federal leaders in the United States, and EU institutions overseeing directive programmes. Finally, Eaton spells out the results it is pursuing: it wants to “set clear flexibility targets at EU level for 2030”, introduce “a single point of contact” to speed grid connections, secure increased federal and state funding for EV charging and R&D on low-NOx and fuel-cell technologies, drive state building-decarbonisation codes, and eliminate SF6 switchgear to help deliver “zero-emissions communities by 2050”. By disclosing the specific policies, the channels it uses, the government bodies it approaches, and the concrete legislative or funding changes it seeks, Eaton demonstrates a comprehensive level of transparency around its climate lobbying activity.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Eaton discloses that “The Governance Committee of Eaton’s Board of Directors meets annually with the vice president of Public Affairs to review our policy on political spending to ensure compliance with our policies,” thereby identifying both a board-level committee and a named executive who oversee the company’s political influence and lobbying activities. The company also states that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” indicating an intention to align advocacy with its climate strategy. In addition, Eaton explains that it “does support lobbying initiatives…by trade associations of which Eaton is a member,” and that no issue-campaign contributions are made “without the approval of the vice president of Public Affairs and chief human resources officer,” which shows at least one concrete internal sign-off mechanism covering both direct and indirect lobbying channels. However, the disclosures focus primarily on political-spending compliance and ethical restrictions—“We do not make contributions on behalf of Eaton to political candidates or parties, even where lawful”—and we found no evidence of a dedicated procedure for assessing the climate-policy positions of those trade associations, no description of how lobbying activities are monitored for alignment beyond the annual policy review, and no published climate-lobbying audit or report. This indicates a moderate governance structure with clear oversight responsibilities and a stated Paris-alignment commitment, but limited detail on systematic monitoring or corrective actions specific to climate-related lobbying.	2