Bayerische Motoren Werke AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	BMW Group has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names specific climate policies and regulations it has engaged with, such as the EU's 'Fit for 55' package, including CO2 fleet legislation, the Energy Taxation Directive (ETD), and the Renewable Energy Directive (RED). It also references its involvement with the California Framework Agreement in the United States, the EPA's Notice of Proposed Rulemaking (NPRM) regarding GHG emission standards, and China's New Energy Vehicle (NEV) mandate. These disclosures provide clear and identifiable references to the policies BMW has lobbied. BMW Group also provides detailed information about its lobbying mechanisms and target entities, including direct engagement with EU Commissioners, discussions with the California Air Resources Board (CARB) and the EPA, and participation in trade associations like ACEA and VDA. Furthermore, the company highlights its involvement in platforms such as the China Association of Automobile Manufacturers (CAAM) and its Representative Offices in various countries, demonstrating transparency in both the mechanisms and targets of its lobbying efforts. Finally, BMW Group has been explicit about the policy outcomes it seeks, such as ambitious CO2 fleet reduction targets, binding targets for charging and hydrogen refueling infrastructure, and incentives for zero-emission mobility. In the United States, it supports extending tax benefits for electrified vehicles, while in China, it advocates for stable incentives to accelerate NEV adoption and green hydrogen incentivization. These disclosures clearly outline the policy changes and goals the company aims to achieve, reflecting a transparent articulation of desired policy changes and outcomes.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	BMW Group presents a structured internal approach to ensuring that its lobbying activities are aligned with its climate change strategy. One detailed disclosure states that "BMW Group's positions regarding global legislative issues arising from our engagement with policy makers at the market level is centrally coordinated in Munich," and further explains that positions are developed collaboratively between central departments—with input from the Vice President of Sustainability, the Vice President for Government and External Affairs, and final oversight by the Chairman of the Board of Management before presentation to a senior decision‐making circle. This clearly demonstrates that the company has established oversight and internal coordination mechanisms covering both direct and indirect lobbying efforts. However, while there is clear evidence of centralized coordination and some efforts to address deviations by actively engaging with affairs offices, other disclosures suggest that the overall process lacks detailed public reporting, comprehensive monitoring mechanisms, or formal lobbying audits. As a result, BMW Group exhibits strong governance through defined processes and accountability channels, though further elaboration on monitoring and transparency could enhance the robustness of its climate lobbying governance.	3