Illinois Tool Works Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate Illinois Tool Works Inc. provides a moderate level of transparency on its climate-related lobbying. It explicitly identifies two pieces of legislation that it has engaged on – the “Scoping Plan for Reduction of Short-Lived Climate Pollutants by 2030,” which covers the phase-out of F-gases in several U.S. states, and “California Senate Bill No. 54.” The company also discloses one concrete channel of influence, stating that “we interacted with members of the CA assembly on the pending legislation in 2021,” which confirms direct engagement and names the policymaking body, although it does not elaborate on additional mechanisms or targets beyond this single example. On desired outcomes, it is clear that the company “support[s] … a new F-gas regulation compelling high GWP transition matching federal regulatory efforts,” while noting its “neutral” stance on SB 54 and that it “did not put forth a view,” thereby explaining both when it is advocating for change and when it is not. Taken together, the disclosures outline the main policies addressed and the core objective sought for F-gas rules, but provide only limited detail on the variety of lobbying methods employed or on additional policy goals, leaving the overall picture moderately detailed rather than comprehensive. 2
Lobbying Governance
Overall Assessment Comment Score
Limited Illinois Tool Works provides only high-level statements about its lobbying practices, focusing primarily on compliance rather than alignment with its climate strategy. ITW’s Government Affairs Policy “prohibits the use of company assets or funds for political purposes” and clarifies that it “does not have a political action committee,” while all lobbying costs “are disclosed in our annual lobbying reports filed with the Clerk of the U.S. House of Representatives.” The company states that “we rely on the individual businesses that engage with trade associations to ensure that the engagement activities are consistent with ITW's overall strategy,” but offers no details on any centralized review or approval process. Although the “Board has direct oversight of the company’s sustainability strategy,” there is no indication that this oversight extends to its lobbying or engagement activities. ITW also confirms that it has “no public commitment or position statement to conduct [engagement] activities in line with the goals of the Paris Agreement” and “does not plan to have one in the next two years,” suggesting that climate considerations are not formally embedded in its lobbying governance. 1