Bayerische Motoren Werke AG

The BMW Group has been listed in the European Union's Transparency Register since 2008 (REG. Number 7193977808-18): number of employees, budget allocated to influencing European legislative processes, areas of interest, details of association memberships. Since 2022, the lobby register legislation of the German Bundestag and Bavarian State Parliament has been in force. BMW AG is listed in the lobby registers of the German Bundestag (R002370) and of the Bavarian State Parliament (DEBYLT007F). [...] PROCESS TO ENSURE A COMMON APPROACH: The company engages in active, open and transparent dialogue with decision-makers and political and trade union representatives as well as representatives of various associations and non-governmental organisations (NGOs) to help shape the political framework conditions for its business activities in a constructive, transparent manner. The BMW Group is a member of numerous associations in various countries. While these memberships and the commitment of the BMW Group are voluntary in most cases, this cooperation may also be based on statutory requirements in individual instances, e.g. for the Chamber of Commerce and Industry for Munich and Upper Bavaria (IHK München, Oberbayern). BMW Group's positions regarding global legislative issues arising from our engagement with policy makers at the market level is centrally coordinated in Munich. Positions are worked out with the participation of corresponding central departments, e.g. the department within the strategy unit responsible for monitoring and further developing CO2 targets for each product line and each new vehicle project or the strategy unit responsible for sustainability and environmental protection, and market representatives, respectively. All of our direct and indirect activities that influence policy are CONSISTENT with our overall climate change strategy. The engagement of the BMW Group with associations ranges from board memberships in various association committees and participation in working groups to roles with observer status only. In the case that the BMW Group observes deviations between the positions of the associations and those of the company, the company enters into a dialogue to improve the alignment. The BMW Group brings the positions of the company into the associations' opinion-forming processes, thereby actively participating in discussions on key strategic topics such as climate protection, human rights, the circular economy, carbon footprint reduction to achieve climate goals under the Paris Agreement. Our Representative Offices in Berlin, Brussels, Beijing, London, Washington DC, Sacramento, Tokyo, Delhi, Singapore, Mexico, Seoul, Sao Paulo, Moscow and Thailand are focal points of direct communication with political decision-makers and NGOs. These structures and processes ensure that all engagement activities are in line with the BMW Group climate change strategy.

Both in the Audit Committee and in the Supervisory Board, the Chief Compliance Officer used his annual report to update us on the further development of the BMW Group's international compliance organisation, enhanced monitoring as part of the compliance risk assessment process and the ongoing measures regarding communication with BMW Group employees. He emphasised that external certification in accordance with Auditing Standard 890 of the Institute of Public Auditors in Germany (IDW) in November 2024 confirmed the full appropriateness and effectiveness of the Compliance Management System in terms of anti-corruption and antitrust compliance. The specific risk analysis required by law in accordance with the Supply Chain Due Diligence Act was performed and follow-up action taken. The report also addressed the handling of individual cases. Furthermore, the members of the Supervisory Board were provided with additional information on the topics of anti-corruption and lobbying. [...] Moreover, the Board of Management regularly informed the Supervisory Board regarding the latest developments in relation to **international trade policy and regulation**. This included, in particular, the current status of the European Commission's anti-subsidy investigation and of EU import duties on all-electric vehicles from China, as well as the impact of these measures on the BMW Group. We also held regular discussions on the further development of the EU7 emissions standard and the EU regulations on fleet carbon emissions.

The BMW Group is a member of selected trade and industry associations and stakeholder groups that address various issues relevant to its business success. During their opinion-forming processes, we contribute our company's point of view through active participation in discussions on key strategic topics. These include climate protection, human rights, the circular economy, carbon footprint reductions to achieve targets of the Paris Climate Agreement and transparent supply chain management. As a member of relevant associations, we advocate for alignment with the targets of the Paris Climate Agreement. [...] The BMW Group is a full member of Manufacturer Group I (Automotive Manufacturers), which brings together more than 650 carmakers and suppliers. As a VDA member, we are active in the various association bodies, including the Management Board, committees, working groups and steering committees. [...] Senior executives from BMW of North America are lead members of the Administrative Board, and members of the Executive Committee and Strategic Planning Committee. In partnering with Auto Innovators, BMW of North America has advanced important legislation pertaining to autonomous vehicles, the right to repair and data privacy, to name a few. [...] The BMW Group China also works closely with the Beijing offices of VDA and ACEA, to actively engage in dialogue with policymakers on the relevant legislation. We also leverage industry think-tanks to voice BMW Group positions. These think-tanks include the China Automotive Technology and Research Center (CATARC), China Society of Automotive Engineers (SAE China) and the China Electric Vehicle Association (EV100).

The first part of the report presents the Code of Conduct for the Company's global advocacy organisation and the policy con­cerning cooperation with trade associations. An overview of the BMW Group's policy organisation and existing transparency registers is also provided. [...] The company leads an active, open and transparent dialogue with ­political decision-makers, representatives of trade unions, associations and non-governmental organisations in order to shape the political framework for its business activities in a constructive and transparent manner. [...] The BMW Group's level of engagement in associations ranges from board memberships in association committees to participation in work­ ing groups to observer status only. In any case, the company strives to align with the respective associations on positions for relevant strategic topics. In the case that the BMW Group observes deviations between association and company positions, the company actively engages with [...] The policy structures endeavour to achieve the highest possible stan­ dards of transparency and credibility in their actions, and to ensure they work on the basis of the facts. The scope and nature of interactions with external stakeholders are shaped by comprehensive compliance rules that apply throughout the Company. [...] The BMW Group has been listed in the ↗ European Commission's EU Transpar­ency Register since 2008. The Company provides information on the ­number of employees and the budgets it allocates to influencing Euro­pean legislative processes and the areas of relevance to the BMW Group, as well as details of its memberships of associations relevant to [...] At the BMW Group, the Corporate Communications and Governmental Affairs department is responsible for understanding the values and aims of the people around us, managing relationships, and communicating with stakeholders and organisations. The government affairs organisation within the BMW Group is an ­integral component of this department. It is responsible for our relation­ships with political and regulatory stakeholders and, in some cases, NGOs and the scientific community in relevant markets worldwide. The BMW Group's government affairs work is closely integrated into its ­Corporate Communications department, ensuring that our core political messages and positions remain consistent and transparent. [...] The Group's central government affairs function, which is based in ­Munich, manages exchanges with policymakers and represents BMW Group's interests with regard to three broad areas, specifically E-Mobility & Environment, Trade & Geopolitics and Digital Car & Mobil­ity. In addition, relationships with core automobile manufacturers' as­ sociations such as the German Association of the Automotive Industry (VDA) and the European Automobile Manufacturers' Association (ACEA) are also coordinated in Munich. [...] BMW AG is also entered in these registers. It provides extensive information about its political activities and its work with associations, as well as its financial expenditure in connection with political lobbying in accordance with the relevant requirements. [...] The BMW Group supports the creation of transparency and lobbying registers. They contribute to transparency as well as increasing trust in the democratic legislative process and in the political work of all those involved in the legislative process.

The BMW Group maintains an active, open and transparent dialogue with representatives of politics, trade unions, associations and non-governmental organisations (NGOs). The aim is to play a constructive and transparent role in helping shape the general political framework regarding the Group's business activities including climate change issues. [...] Proposals for the executive body concerning climate-relevant issues are aligned between the Vice President of Sustainability, Mobility being under the direct supervision of the Chairman of the Board of Management and the Vice President for Government and External Affairs before they are presented in the Strategy & Structure Circle, which prepares decisions to be made by the Board of Management. In this way all of our direct and indirect activities that influence policy are CONSISTENT with our overall climate change strategy.

The BMW Group is committed to achieving ambitious yet realistic environmental policy targets worldwide that meet the Paris Climate Agreement. These include a fully climate-neutral value chain by 2050 at the latest. In our work with major industry associations (VDA, ACEA, Alliance for Automotive Innovation, CAAM), we advocate for aligning association activities with the Paris Climate Agreement. [...] BMW of North America remains in an alliance with the State of California in its adherence to the California Framework Agreement, signed in 2019, which introduced significantly higher stringency levels than the greenhouse gas (GHG) levels of the former Trump administration. The continued cooperation with California has allowed the BMW Group to enhance its already constructive working-level dialogue with both the California Air Resources Board and the EPA. This framework agreement is still in place today. [...] The BMW Group has spoken with representatives of the Chinese government – such as the Ministry of Industry and Information Technology and the Ministry of Commerce – about climate policy at various meetings. Discussions focused on the further expansion of the fast-charging network, incentives to increase the market acceptance of electric vehicles, and the decarbonisation of supply chains.

### Collaboration with associations.
To help form the policies that shape our business environment, the BMW Group works constructively and openly, engaging in active, transparent dialogue with decision-makers and representatives from politics, trade unions, and various associations and NGOs. We are a member of multiple associations in different countries, mostly on a voluntary basis. In some cases, however, the cooperation may be statutory, for example with the Chamber of Commerce and Industry for Munich and Upper Bavaria (IHK München, Oberbayern) and the Chamber of Commerce and Industry of Berlin (IHK Berlin).

Our engagement with associations ranges from board memberships in various committees and participation in working groups to observer roles. Our goal throughout is to achieve mutual alignment on important strategic topics with the respective associations. If we notice our positions diverging, we raise the issue with the association concerned and discuss it to improve alignment. We contribute our company's point of view to decision-making by the associations through active participation in discussions on key strategic topics including climate protection, human rights, the circular economy, carbon footprint reductions and transparent supply chain management. We advocate for the targets of the Paris Climate Agreement in associations and organisations we are a member of. [...] ### Governmental affairs - at a glance.
At the BMW Group, our understanding of the values and aims of those around us, our relationship management and stakeholder communications are managed by our Corporate and Governmental Affairs section.

Within Corporate and Governmental Affairs, our Governmental Affairs department is responsible for our relationships with political and regulatory stakeholders, NGOs and the scientific community worldwide and ensures the consistency and transparency of our core political messages and positions.

At Governmental Affairs in Munich, communications are organised into three main topic areas: E-mobility & Environment, Trade & Geopolitics, and Digital Cars & Mobility. The aim is to establish uniform, legally compliant framework conditions that leave us sufficient flexibility and agility to develop innovative products. The team in Munich also coordinates our relationships with core automotive manufacturers' associations like the German Association of the Automotive Industry (VDA) and the European Automobile Manufacturers' Association (ACEA).

At the international level, Governmental Affairs is organised into four key regions: Europe, the Americas, China and Asia-Pacific/Africa/Middle East. In selected individual and growth markets, the BMW Group also operates local Governmental Affairs offices and/or employs local staff to interact directly with policymakers and regulators. The offices provide a permanent point of contact for local decision-makers and are available to address queries directly and in the local language – an opportunity our stakeholders are keen to use.

Governmental Affairs strives to ensure the greatest possible transparency as well as fact-based information and credibility. For this reason, a comprehensive set of compliance regulations is in place across the company to govern our contact with external stakeholders and shape the nature of our interactions with them. [...] ### Entries in transparency registers.
Transparency registers for interest groups such as private individuals, companies and NGOs involved in political decision-making vary from country to country and also between regions. They may be voluntary or compulsory, and individuals or organisations seeking to influence political institutions or decision-making can/must register with them. The purpose of these registers is to help increase public trust in politics and maintain transparency over the way lobbyists and representatives exert their influence.

The BMW Group has been listed in the European Union's Transparency Register since 2008. Details are provided of the number of employees and budget allocated to influencing European legislative processes, our areas of interest and details of association memberships relevant to EU policymaking.

Since 2022 the lobby register legislation of the German Bundestag and Bavarian State Parliament has also been in force, providing for the establishment of public lobbying registers. BMW AG is listed in these registers and, in accordance with requirements, we provide detailed information about our political and association work and financial expenditure in connection with political lobbying.

The BMW Group welcomes the establishment of transparency and lobbying registers of this kind, as they help to increase transparency as well as trust in the democratic legislative process and the political work of all those involved in it.

Mit ihrem Klima-Engagement Bericht gibt die BMW Group ihren Stake­holdern einen kompakten Überblick über ihre wichtigsten klimapoliti­schen Positionen und Aktivitäten. Im ersten Teil des Berichts wird der Verhaltenskodex für die weltweiten Interessenvertretungen des Unter­nehmens sowie die Policy zur Kooperation mit Wirtschaftsverbänden dargestellt. Dazu wird ein Überblick über die Politikorganisation der BMW Group gegeben und auf bestehende Transparenzregister hinge­wiesen. [...] Die Politikorganisation strebt in ihrem Handeln nach höchstmöglicher Transparenz, Faktenorientierung und Glaubwürdigkeit. Unternehmens­weit gelten umfassende Compliance-Regeln für den Umgang mit externen Stakeholdern, die den Umfang und die Art des Austausches prägen. [...] Bereits seit 2008 ist die BMW Group daher im ↗ EU-Transparenzregister der Europäischen Kommission eingetragen und gibt Auskunft darüber, mit wieviel Personal- und Budgetaufwand sie sich in welchen für sie relevanten Themenbereichen in europäische Gesetzgebungsprozesse einbringt oder in welchen EU-politisch relevanten Verbänden sie Mitglied ist. Seit dem 1. Januar 2022 sind ebenfalls die Lobbyregistergesetze des ↗ Deutschen Bundestages und der ↗ Bayerischen Staatsregierung in Kraft, welche die Einrichtung von öffentlichen Lobbyregistern vorsehen. Die BMW AG ist auch in diesen Registern eingetragen und macht hier umfangreiche Angaben zu ihrer Politik- und Verbandsarbeit sowie zu finanziellen Auf­wendungen im Zusammenhang mit politischer Interessenvertretung entsprechend den jeweiligen Anforderungen. [...] Das Verstehen der Überzeugungen und Ziele unseres Umfeldes, das Management der Beziehungen und die Kommunikation zu den Stake­holdern und Organisationen werden bei der BMW Group ganzheitlich durch den Bereich "Konzernkommunikation und Politik" geführt. Die Politikorganisation der BMW Group ist dabei integraler Bestandteil dieses Bereiches und verantwortet die Beziehungen zu politisch-regu­latorischen Stakeholdern sowie teilweise auch NGOs und der Wissen­schaft in relevanten Märkten weltweit. Die feste Integration der Politik­arbeit der BMW Group in den Bereich der Konzernkommunikation stellt dabei einmal mehr die Durchgängigkeit und Transparenz unserer poli­tischen Kernbotschaften und Positionen sicher.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]PROCESS TO ENSURE A COMMON APPROACH:
BMW Group's positions regarding global legislative issues arising from our engagement with policy makers at the market level is centrally coordinated in Munich. Positions are worked out with the participation of corresponding central departments, e.g. the department within the Strategy unit responsible for monitoring and further developing CO2 targets for each product line and each new vehicle project or the strategy unit responsible for sustainability and environmental protection, and market representatives, respectively.
Moreover, proposals for the executive body concerning climate-relevant issues are aligned between the Vice President of Sustainability, Mobility being under the direct supervision of the Chairman of the Board of Management and the Vice President for Government and External Affairs before they are presented in the Strategy & Structure Circle, which prepares decisions to be made by the Board of Management. In this way all of our direct and indirect activities that influence policy are CONSISTENT with our overall climate change strategy.

The BMW Group maintains an active, open and transparent dialogue with representatives of politics, trade unions, associations and non-governmental organisations (NGOs). The aim is to play a constructive and transparent role in helping shape the general political framework regarding the Group's business activities including climate change issues.

We discuss policy issues with various national and international trade organizations, NGOs, scientific institutions etc. Our Representative Offices in Berlin, Brussels, Beijing, London, Washington DC, Sacramento, Tokyo, Delhi, Singapore, Mexico, Seoul, Sao Paulo, Moscow and Thailand are focal points of direct communication with political decision-makers and NGOs. In addition to major markets with a Representative Office, the BMW Group National Sales Companies are active in establishing political contacts and engage in political dialogue in the respective markets in 43 countries. The same applies to Regional Offices serving importer markets and to our manufacturing facilities.
These structures and processes ensure that all engagement activities are in line with the BMW Group climate change strategy.

# Collaboration with Key Automotive Associations

## Collaboration with Associations

The BMW Group is a member of selected trade and industry associations and stakeholder groups that address various issues relevant to its business success. During their opinion-forming processes, we contribute our company's point of view through active participation in discussions on key strategic topics. These include climate protection, human rights, the circular economy, carbon footprint reductions to achieve targets of the Paris Climate Agreement and transparent supply chain management. As a member of relevant associations, we advocate for alignment with the targets of the Paris Climate Agreement.

## German Association of the Automotive Industry (VDA)

The BMW Group is a full member of Manufacturer Group I (Automotive Manufacturers), which brings together more than 650 carmakers and suppliers. As a VDA member, we are active in the various association bodies, including the Management Board, committees, working groups and steering committees.

Key focal points of the VDA's work include data, international trade, drivetrain technologies, taxation and regulation, and market-specific policy issues such as promoting research and development.

In the field of regulation and drivetrain technologies, the BMW Group is committed to promoting sustainable goals and legislation, in particular with a view to securing political support for our goal of climate neutrality by 2050. Securing this support means representing our interests to policymakers via the VDA on issues such as establishing the necessary preconditions for electromobility, charging infrastructure, the hydrogen industry and secure supply chains and raw material supplies. In addition to our clear
access to data is via secure, protected, equitable-access platforms so that highly automated vehicles remain secure for users in the future.

In international trade, the BMW Group is committed to a comprehensive European trade policy that ensures free access to factors of production and safeguards the necessary supplies of raw materials to European plants.

## EUROPEAN AUTOMOBILE MANUFACTURERS' ASSOCIATION (ACEA)

Based in Brussels, Belgium, the European Automobile Manufacturers' Association (ACEA) represents 15 major European-based car, van, truck and bus manufacturers. It is the foremost interest group of our industry for accompanying legislative processes in the European Union. As ACEA president from 2021 – 2022, Oliver Zipse, Chairman of the Board of Management at BMW AG, was actively involved in political opinion-forming in a wide range of legislative initiatives. A primary focus was the EU Commission's "Fit for 55" dossiers, whose regulations are intended to lay the groundwork for the successful transformation of the European automotive industry.

Here, the stakeholder group's goal was to continue achieving maximum impact in the fight against climate change while maintaining and increasing the sector's competitiveness. During the decision-making process at the European level, ACEA provided support via numerous discussion formats, from fleet CO2 emissions legislation and regulations enabling the public and private charging infrastructure for electromobility, to issues of raw material dependency.

In addition, our work in ACEA focuses on the legal framework regulating the use of the latest innovations across the full range
CAAMIC conferences facilitate the exchange of information and help establish common positions. CAAM then aligns these with domestic OEMs and joint venture committees, and advocates for the industry position with policymakers, for instance by submitting position papers and policy proposals, and attending discussions with them.

The BMW Group China also works closely with the Beijing offices of VDA and ACEA, to actively engage in dialogue with policymakers on the relevant legislation. We also leverage industry think-tanks to voice BMW Group positions. These think-tanks include the China Automotive Technology and Research Center (CATARC), China Society of Automotive Engineers (SAE China) and the China Electric Vehicle Association (EV100).

BMW AG, May 2024
**Contact:** governmentaffairs@bmwgroup.com

 

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