Bayer AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Bayer publicly describes a detailed, formal governance system that monitors and enforces alignment of both its direct and indirect climate-related lobbying with its Paris-aligned policy positions, and it publishes dedicated reviews of that alignment. The company states that its Code of Conduct for Responsible Lobbying provides us with binding rules for our involvement in political matters and creates transparency in our collaboration with representatives of political institutions, while the Bayer Industry Association Climate Review compares the climate policy positions of our industry associations with our own climate goals and is updated every two years, demonstrating an explicit methodology for assessing indirect lobbying. Oversight responsibilities are clearly assigned: The highest level of responsibility for climate-related issues lies with Bayers CEO who also functions as Bayers Chief Sustainability Officer with final actions approved by the wider Public Affairs, Science and Sustainability leadership, and The project sponsor is Werner Baumann, Chairman of the Board of Management and Chief Sustainability Officer. Monitoring and escalation steps are described in detail: Where engagement does not result in a satisfactory change in policy Bayer will pursue a policy of remediation Ultimatum Exit, a process that has already resulted in the company terminated our membership in NAM as part of ongoing cost savings measures in June 2022. Direct lobbying is also reviewed and disclosed; the firm annually publish[es] an overview of our engagement activities on climate policy and its 2023 Political Advocacy Transparency Report describ[es] our activities, avenues of engagement, as well as disclosures on our expenditures and top advocacy topics. Governance mechanisms extend to training, internal audits and whistle-blowing channels: Bayer lobbyists will be provided with appropriate training content Suspected compliance violations can be reported anonymously if desired to a compliance hotline. This combination of a publicly available climate-lobbying review, explicit remediation/exit procedures, named executive and board-level oversight, annual disclosure of direct advocacy, and embedded compliance controls indicates comprehensive governance of climate-related lobbying. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Bayer publicly describes a detailed, formal governance system that monitors and enforces alignment of both its direct and indirect climate-related lobbying with its Paris-aligned policy positions, and it publishes dedicated reviews of that alignment. The company states that its Code of Conduct for Responsible Lobbying provides us with binding rules for our involvement in political matters and creates transparency in our collaboration with representatives of political institutions, while the Bayer Industry Association Climate Review compares the climate policy positions of our industry associations with our own climate goals and is updated every two years, demonstrating an explicit methodology for assessing indirect lobbying. Oversight responsibilities are clearly assigned: The highest level of responsibility for climate-related issues lies with Bayers CEO who also functions as Bayers Chief Sustainability Officer with final actions approved by the wider Public Affairs, Science and Sustainability leadership, and The project sponsor is Werner Baumann, Chairman of the Board of Management and Chief Sustainability Officer. Monitoring and escalation steps are described in detail: Where engagement does not result in a satisfactory change in policy Bayer will pursue a policy of remediation Ultimatum Exit, a process that has already resulted in the company terminated our membership in NAM as part of ongoing cost savings measures in June 2022. Direct lobbying is also reviewed and disclosed; the firm annually publish[es] an overview of our engagement activities on climate policy and its 2023 Political Advocacy Transparency Report describ[es] our activities, avenues of engagement, as well as disclosures on our expenditures and top advocacy topics. Governance mechanisms extend to training, internal audits and whistle-blowing channels: Bayer lobbyists will be provided with appropriate training content Suspected compliance violations can be reported anonymously if desired to a compliance hotline. This combination of a publicly available climate-lobbying review, explicit remediation/exit procedures, named executive and board-level oversight, annual disclosure of direct advocacy, and embedded compliance controls indicates comprehensive governance of climate-related lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Bayer AG provides highly detailed and wide-ranging disclosure of its climate-policy lobbying. It names a broad suite of specific measures it has tried to influence, including the U.S. Inflation Reduction Act and Growing Climate Solutions Act, revisions to Regulation (EU) 2018/841 on land-use and forestry, the EU carbon-removal certification framework, and legislative changes to the German Building Code to speed renewable-energy deployment, as well as its public support for the EU ETS, the EU Green Deal and the International Climate Club initiative. The company is equally explicit about how and where it lobbies: it reports bilateral meetings, CEO round-tables and industry-association sessions with identified officials such as “Chancellor Olaf Scholz, Economy Minister Robert Habeck, and several members of parliament,” testimony before the U.S. House Agriculture Committee, formal submissions recorded in the EU Transparency Register, and direct collaboration with bodies like the U.S. Department of Agriculture and China’s Ministry of Agriculture and Rural Affairs. Bayer also lists indirect channels, for example its work through trade bodies that are examined in its Industry Association Climate Review, and confirms that “all our lobbying activity on climate change at the federal level has been publicly disclosed through the Secretary of the Senate and Clerk of the House.” Finally, the disclosures spell out the concrete outcomes sought: embedding “climate neutrality into both, industry and agriculture policy strategies,” accelerating renewable-energy expansion on industrial sites, securing harmonised Scope 3 reporting in the U.S. Farm Bill, inserting removal-incentive mechanisms into the EU’s LULUCF rules, and creating certification systems so farmers can monetise verified carbon credits. Statements such as “Bayer fundamentally supports the energy transition and supports the goal of the Paris Agreement” and the call for “The establishment of an international climate club to introduce uniform standards” further clarify its policy stance. Together, these elements demonstrate a comprehensive level of transparency across the policies lobbied, the mechanisms used and the specific outcomes pursued.	A