Bayer AG

Lobbying Governance

AI Extracted Evidence Snippet Source

**Bayer setzt sich für eine offene Debatte und fördernde Rahmenbedingungen zugunsten innovativer Lösungen für Gesundheit und Ernährung ein. Dabei haben wir verbindliche Regeln für unser Engagement im politischen Raum festgelegt und sind transparent in unserer Zusammenarbeit mit Vertretern politischer Institutionen.** [...] Bayer's Societal Engagement (BASE) Prinzipien bilden die Grundlagen für unser gesamtes politisches Engagement und prägen den Umgang mit Stakeholdern wie Gesetzgebern, Aufsichtsbehörden und zivilgesellschaftlichen Organisationen. Unser "Verhaltenskodex für verantwortungsvolles Lobbying" gibt uns darüber hinaus verbindliche Regeln für unser Engagement in politischen Angelegenheiten vor und schafft Transparenz in der Zusammenarbeit mit Repräsentanten politischer Institutionen. Beide Richtlinien stellen unseren Leitkompass für transparentes und faires politisches Engagement und Lobbying dar. [...] Angesichts unserer ehrgeizigen Klimaziele veröffentlichen wir jährlich eine Übersicht unseres klimapolitischen Engagements. Zudem hinterfragen wir regelmäßig kritisch unsere Mitgliedschaften in relevanten Industrieverbänden sowie deren Positionen bzgl. klimapolitischer Maßnahmen. Wo wir eine Diskrepanz zwischen unseren Klimazielen und denen unserer Industrieverbände feststellen, werden wir Maßnahmen ergreifen, um diese Lücke zu schließen. In unserem jährlichen Bayer Climate Advocacy Report legen wir unsere Erfolge als auch die noch vor uns liegende Arbeit offen. [...] Public Affairs ist Teil der Funktion Public Affairs, Science & Sustainability and Health, Safety & Environment. Das vom Global Public Affairs Head geleitete Global Public Affairs Leadership Team, bestehend aus den jeweiligen Public Affairs Heads der Divisionen und zentralen Verbindungsbüros, entwickelt die Public Affairs Prioritäten und Strategien und ist für das Talent Management zuständig. Für die konkrete Umsetzung der Interessenvertretung vor Ort, das Einhalten ethischer und rechtlicher Kriterien und die Herstellung von Transparenz sind die jeweiligen Ländervertretungen verantwortlich.

https://www.bayer.com/de/nachhaltigkeit/politische-grundsaetze-und-positionen

Bayer publishes Update on Industry Association Climate Engagement Review

Bayer is dedicated to a climate policy that is in harmony with our ambitious climate targets and therefore advocate for decarbonization measures in line with the Paris Agreement. In accordance with our ambitions, we regularly examine critically our memberships in relevant industrial associations and their positions and actions affecting climate policy both internally and externally.

Bayer started publishing its Industry Association Climate Review in 2021. Find the updated 2022 report here, and more information on our website.

https://www.bayer.com/en/sustainability/latest-updates-on-sustainability

In our 2021 Industry Association Climate Review we identified a total of 10 material misalignments in positions of our associations. These material misalignments are connected to six different associations located in five different countries. Instances of material misalignment between Bayer's climate policy positions and those of an industry association identified in our assessment have made that organization a priority for Bayer to engage with. As outlined in last year's comprehensive report, the process of engagement covers examining and understanding the reasoning of the association, proactively engaging with the association, assessing the impact opportunities, and influencing a position change. Where the engagement process does not result in a satisfactory change in policy or where Bayer assesses that alignment is unlikely to be possible, we would start a remediation process. Overall, we see either a change in the respective association or assess that we can make a greater impact on their position by further engaging rather than leaving the association. Thus, we decided to remain in the associations and to not start the remediation phase except for the National Association of Manufacturers (NAM) in the U.S. We terminated our membership in NAM as part of ongoing cost savings measures in June 2022. In the corresponding decision process, we factor in a variety of different aspects which among many others also include the climate position of the association.

https://www.bayer.com/sites/default/files/Bayer_Industry%20Association%20Climate%20Engagement_rg_v05_fin.pdf

###### Bayer's Sustainability Governance framework
Holistic approach ensuring sustainable execution and advancement

Independent Oversight Regulations & Processes

###### Reports on GMOs, UNGC adherence, and Crop Science Sustainability Progress

New Bioethics Council established

Extension of Bayer Science Collaboration Explorer with US launch

OpenLabs 360º launched

Progress on climate sphere (e.g., publication of offsetting approach, updated supplier code of conduct, and industry asssociation climate review)

###### Supervisory Board
ESG Committee

Sustainability Council &
Bioethics Council

External & Internal Audits

Reporting acc. to relevant frameworks

###### Broad group-wide policy-based framework

ESG included in Compensation

Integrated Governance CEO as Chief
Framework
Sustainability Officer

Sustainability Decision Committee

Topic specific transparency initiatives

###### Reporting & Transparency Organizational Setup

https://www.bayer.com/sites/default/files/2023-03-16%20ESG%20Investor%20Update%20Webinar_Final.pdf

Bayer is dedicated to a climate policy that is in harmony with our ambitious climate targets and therefore advocate for decarbonization measures in line with the Paris Agreement. In accordance with our ambitions, we regularly examine critically our memberships in relevant industrial associations and their positions and actions affecting climate policy both internally and externally. Further information here: [This Is How We Protect the Climate | Bayer Global.](https://www.bayer.com/en/sustainability/climate-protection) [...] Additionally, we are reporting about our political engagement and our activity in different initiatives and associations. [Our Political Principles and Positions | Bayer Global.](https://www.bayer.com/en/sustainability/political-principles-and-positions)

https://www.bayer.com/sites/default/files/2023-05-16_Bayer_Just%20Transition_publication.pdf

#### 2.6 Climate policy engagement and management

Externally, we advocate for a climate position in line with our ambitious targets and demand that our partners also undertake decarbonization measures in accordance with the Paris Agreement. We critically scrutinize our memberships in relevant industry associations and their positions as regards climate policy measures. [To ensure transparency in this connection, we published an Industry Association Climate Review for the first](https://www.bayer.com/sites/default/files/Bayer%20Industry%20Association%20Climate%20Review%202021.pdf) time in 2021.

This report compares the climate policy positions of our industry associations with our own climate goals. As our industry associations represent us in the public debate, we disclose where we agree with these positions and where they diverge from ours. It is of paramount importance to us that we maintain a dialogue with our associations to achieve an amicable solution. Where differences exist, dialogue enables us to take measures to close these gaps.

The analysis of 2021 represents a first step and forms the basis for Bayer's further efforts to advocate through its member associations for scientifically founded policies to combat climate change. In producing this analysis, we worked together with Climate Action 100+, an investor initiative that cooperates with the world's biggest industrial companies on the issue of climate change.

https://www.bayer.com/sites/default/files/2022-03/Bayer-tcfd-report-2021.pdf

Bayer is dedicated to a climate policy that is in harmony with our ambitious climate targets. Therefore, we advocate for decarbonization measures in line with the Paris Agreement and specifically with the goal to limit global warming to 1.5 degrees Celsius above pre-industrial levels as outlined in our Global Climate Policy Position. Our further climate policy positions and engagement activities related to specific policy initiatives in countries are guided by this global position.

To ensure transparency in our climate policy engagement, we annually publish an overview of our engagement activities on climate policy. Additionally, we regularly examine critically our memberships in relevant industrial associations and their positions and actions affecting climate policy both internally and externally in accordance with our ambitions.

Consequently, Bayer started publishing its Industry Association Climate Review on a yearly basis in 2021. The review assesses the alignment of our industry associations' climate positions with our own commitments on climate change. Our industry associations represent us in the public debate, so we need to be transparent about where our climate-change goals are aligned with their actions and where we have different views. In compiling the analysis, we have engaged with Climate Action 100+, an investor-led initiative working with the world's largest corporation on climate change. Further details on the review approach are provided in the 2021 Report.

The 2021 review is the first step and forms the basis for Bayer's continued commitment to advocacy for science-based policies addressing climate change through its member associations. Where we find misalignment between our climate ambitions and those of our industry associations, we will take measures to bridge that gap. To disclose our successes and the work that still lies ahead, please see our Engagement Update 2023 and second comprehensive Industry Association Climate Review 2023.

https://www.bayer.com/en/sustainability/climate-commitment-net-zero-2050

In the U.S., all federal lobbying and associated costs are disclosed through Secretary of the Senate and the Clerk of the House (see here). In 2023, Bayer's climate change lobbying activities in the US focused on advocating for inclusion of harmonized Scope 3 Greenhouse Gas emissions reporting, ESG and sustainable investment frameworks, best practices and protocols for voluntary carbon markets, education about direct seeded rice projects in Southeast Asia to reduce associated methane emissions, and retention of federal funding for Partnerships for Climate Smart Commodities in the Farm Bill, which funds a number of grants received by our partners. [...] At the EU, Bayer publishes the main targeted legislative and policy initiatives and all contributions to public consultations, roadmaps as well as meetings with the political level at the European Commission in the EU Transparency Register (see here). In 2023, we continued to be involved in activities on carbon farming and carbon removal certification. Bayer responded to public consultations regarding the European Commission proposals on the carbon removal certification framework regulation and the soil monitoring and resilience directive, as well as responded to a stakeholder survey on pricing of agricultural emissions. Bayer co-organised an event together with two European trade associations, CEMA and ECAF, called "What about Regenerative Agriculture? A Fact-finding Mission on Sustainable Farming" as well as co-organising an event titled "Rethinking Arable Farming in a Changing Climate: the agronomy of climate smart farming to deliver on the EU Green Deal" with Yara, Netafim, and ELO. Moreover Bayer sponsored or co-organized jointly with POLITICO Europe, the climate-related events titled The Future of Food and Farming Summit and the Sustainable Future Week 2023.

https://www.bayer.com/sites/default/files/overview-of-our-engagement-activities-on-climate-policy-in-2023.pdf

Bayer's commitment to ensuring transparent lobbying forms part of our BASE principles. In line with this, our Code of Conduct for Responsible Lobbying sets out binding rules for our involvement in political matters, covers compliance-relevant risks and creates transparency in our interactions with the representatives of political institutions. [...] As set out in this Group regulation, Bayer as a company does not make any donations to political parties, politicians or candidates for political office. An exception to this rule existed in the United States until the end of 2021. Direct and indirect donations by companies to political candidates and parties are prohibited at the federal level. Against this background, employees of numerous companies support individual candidates for parliamentary office by making private donations through political action committees, or PACs. These voluntary donations are made only by employees, not the company. PACs are separate, segregated funds governed by employees and further regulated by the U.S. Federal Election Commission (FEC) and some state governments. [...] Decisions on how these contributions are allocated are made by an independent committee composed of employees. At BAYERPAC, the name of the corresponding committee at Bayer, new allocation criteria were introduced in 2020 [to reflect societal challenges, among other factors. For ex-](https://disclosurespreview.house.gov)ample, candidates' positions on issues such as climate change and the protection of biodiversity play an important role here. BAYERPAC also undertakes to support candidates from both parties. These donations are subject to stringent conditions and mandatory transparency measures. The BAYERPAC contributions are regularly reported to the U.S. Federal Election Commission (FEC). Full details can be viewed on the FEC website. BAYERPAC does not support presidential candidates. A total of US$159,498 was donated [to political candidates at all levels through BAYERPAC in 2021.](https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=3523776801-85&locale=en#en) Bayer made corporate donations at the state level in the United States until the end of 2021. These amounted to a [total of US$20,500 in 2021. Since the beginning of 2022, a](https://www.bayer.com/en/corporate-governance/approach-to-tax)new Group regulation has applied at Bayer, according to which the company will not make any political donations in any country in the world. [...] For Bayer, national liaison offices are key touchpoints between the company and political stakeholders. We publish details of material costs, project expenses, employee numbers and any of the other statistics required in each country, for example in the transparency registers of the European institutions and the U.S. Congress. In doing so, we go beyond the statutory requirements. For instance, we also publish data for countries such as Germany where – as yet – there is no legal disclosure requirement. In 2021, the costs incurred at the liaison offices totaled approximately €3.0 million in Berlin, Germany; €1.9 million in Brussels, Belgium; €13.0 million in Washington, D.C., United States; €1.0 million in Brasília, Brazil; and €2.1 million in Beijing, China.

https://www.bayer.com/sites/default/files/2022-03/Bayer-Sustainability-Report-2021.pdf

Transparency and good governance are key for us. In that spirit, this first Bayer Industry Association Climate Review is a natural next step. Active engagement in industry associations and trade bodies is vitally important to our business and stakeholder engagement. As Bayer contributes to the global policy discussion on how best to address climate change, we expect our industry partners and trade associations to equally engage. The same also applies to maintaining standards of responsible lobbying. We are committed to working together to address any identified gaps between our expectations and the activities of the trade associations of which we are a member. [...] The Bayer Industry Association Climate Review will be updated every two years. Based on the findings, we will work together with associations where we see opportunities for increased alignment on our climate policy agendas. Through our actions, we hope to set a new standard for disclosure and reporting on climate policy advocacy. [...] Transparency in climate-related lobbying Transparency is a key priority for Bayer. We are committed to building and strengthening trust by making information accessible from a whole range of areas. In our political engagement, we disclose in-depth information regarding our political activities in the transparency registers operated by the European institutions and the U.S. Congress. Bayer goes beyond the statutory requirements in doing so. For instance, we also publish data for countries where there is no legal publication requirement to do so. This includes climate-related advocacy activity. Our Bayer Societal Engagement (BASE) Principles provide the basis for all our external engagement and shape the way we interact with stakeholders such as legislators, regulators and civil society organizations. Our 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. Together, both guidelines represent our guiding compass for transparent and fair political engagement and lobbying. [...] Governance The highest level of responsibility for climate-related issues lies with Bayer's CEO who also functions as Bayer's Chief Sustainability Officer (CSO). As CSO he is responsible for the groupwide sustainability program including climate-related targets and measures. This includes ultimate oversight for the industry association climate review and engagement process. [...] Methodology A project team comprising Bayer public affairs and sustainability professionals led development of the approach to and delivery of the analysis. An initial phase of activity was the development of measures to define which associations should be included in the report and the policy criteria against which they would be judged. [...] Bayer discussed and aligned its approach with investors involved in the Climate Action 100+ initiative. Climate Action 100+ is an unprecedented investor engagement initiative focused on climate action by the world's largest corporate greenhouse gas emitters. [...] The project is supervised at the most senior levels of the organization and overseen by Bayer's Public Affairs leadership team with final actions approved by the wider Public Affairs, Science and Sustainability leadership. The project sponsor is Werner Baumann, Chairman of the Board of Management and Chief Sustainability Officer. [...] Phase 2: Remediation Process Where engagement does not result in a satisfactory change in policy, or where Bayer assesses that engagement is unlikely to create alignment, Bayer will pursue a policy of remediation. This process will be led by Bayer's global public affairs team, with oversight from Bayer's executive board. The process of remediation will sequentially go through the following steps: Review: Undertake a formal review of membership. This would be accompanied by a public statement setting out the basis of misalignment and Bayer's preferred position, together with a clear timeline for the review and a deadline for a decision on actions to be taken. Further measures: Pursue further measures to exert the influence on a policy change. The key point of assessment will be if the additional steps are successful in achieving policy change. If yes, the process ends here. If not, Bayer will move to ultimatum. Ultimatum: Before deciding to exit, Bayer will prepare an ultimatum and make it clear to the industry association that it intends to leave by a specified date unless the organization undertakes a policy review or changes its policy position. Exit: The final action as part of remediation for Bayer, would be to leave the industry association's membership and to agree an annual review for re-joining based on a future policy change.

https://www.bayer.com/sites/default/files/Bayer%20Industry%20Association%20Climate%20Review%202021.pdf

In the area of scientific affairs, we specified our disclosure on ghostwriting that is strictly prohibited, while we tried to be more specific on our already existing policies on lobbying. We see the increased information need on this topic and are therefore in the process of conducting a consolidated lobbying report. [...] Publication of first Bayer Political Advocacy Transparency Report

https://www.bayer.com/en/sustainability/esg-investor-engagement-activities

The Chairman of the Board of Management holds direct responsibility for climate protection in his role as CSO. In keeping with their level of importance, climate-related topics and Bayer's climate strategy were discussed at three meetings of the Board of Management, two meetings of the Supervisory Board and at two meetings of the ESG Committee of the Supervisory Board in 2022. The Chairman of the Board of Management is supported in this by PASS&HSE and the sustainability departments within the divisions. The divisions handle the operational implementation of the climate protection measures at their sites with the support of the enabling functions. [...] Externally, we advocate for a climate position in line with our ambitious targets and demand that our partners also undertake decarbonization measures in accordance with the Paris Agreement. We critically scrutinize our memberships in industry associations and the CSO decided to publish an Industry Association Climate Review for the first time in 2021, which was continued with the publication of an Engagement Update in 2022.

https://www.bayer.com/sites/default/files/bayer-ag-cdp-climate-2023.pdf

In his role as CSO, the Chairman of the Board of Management is supported by the Public Affairs, Science & Sustainability (PASS) enabling function. He is the superior of the Head of PASS who is responsible for Bayer's sustainability strategy including Bayer's CLIMATE STRATEGY and TARGETS. Relevant topics in the field of sustainability incl. climate-related topics are discussed during their regular meetings. The implementation of our sustainability targets including CLIMATE-RELATED TARGETS is a KEY ELEMENT OF THE ANNUAL PERFORMANCE OBJECTIVES of both. [...] Externally, we advocate for a climate position in line with our ambitious targets and demand that our partners also undertake decarbonization measures in accordance with the Paris Agreement. We critically scrutinize our memberships in industry associations and the CSO decided to publish an Industry Association Climate Review for the first time in 2021.

https://www.bayer.com/sites/default/files/Bayer-AG-CDP-Climate-2022.pdf

Political Advocacy Transparency Report 2023

In our dedicated Report on political advocacy, we describe our activities, avenues of engagement, as well as disclosures on our expenditures and top advocacy topics in our five largest markets. [...] Industry Association Climate Review

The Industry Association Climate Review provides an update on Bayer's climate advocacy activity in our trade association engagement. It sets out how we continue to promote climate-positive policies and how we are trying to find practical ways to support the delivery of the Paris Agreement by engaging and working in partnership with associations across markets.

https://www.bayer.com/en/sustainability/additional-reports

Following last year's Council report, the Council started a discussion with Bayer on responsible advocacy. In line with Bayer's Societal Engagement BASE-Principles, its corporate public affairs / advocacy activities are guided by Code of Conduct for Responsible Lobbying. Bayer is supporting climate-friendly policies through Bayer's industry association membership and has compared the positions of its 65 industry associations with its own positions in the Industry Association Climate Review 2021 and engages to reduce any deviations, see Industry Association Climate Review – Engagement Update 2022. Moreover, transparency is a top priority for Bayer. Bayer is committed to build up and strengthen trust by making information accessible from a whole range of areas including lobbying and political positions (see also Bayer Transparency website). The Council is supportive of Bayer's efforts to increase transparency in the area of political advocacy and make information more accessible. Moreover, the Council urges Bayer to continue to use its influence to change the standpoint of industry associations that are not aligned with Bayer's standpoints on climate policy. In addition, the Council encourages Bayer to continue to adopt a mindset that focuses on promoting policy change by showing data supported value added to people, society and the environment. The Council wants to learn more about Bayer's political positions in selected focus countries and looks forward to continuing and deepening the discussions in 2023.

https://www.bayer.com/sites/default/files/2023-03-31_Sustainability%20Council%20Report%202022_vf.pdf

Procedure No. PAS-PUB-9-315014 Version: 3.0 [...] Bayer employees are responsible for ensuring contracted lobbyists are made aware of the rules outlined in this Procedure and adhere to its rules. [...] Bayer – i.e., its lobbyists – signs up in transparency registers of public institutions, where existing, and discloses relevant information as requested. Bayer supports the introduction of well-balanced transparency rules (e.g., lobbying registers) in political systems where the company represents its interests if these rules are designed to apply to all interest groups engaging in the respective political arena (level-playing field). [...] BAYERPAC, like all Political Action Committees (PACs), is highly regulated, and maintains an independent governance board comprised of Bayer employees from across the businesses. The donations made via BAYERPAC are regularly reported to the U.S. Federal Election Commission and publicly available on the Internet. [...] Suspected compliance violations, such as a violation of this code of conduct, can be reported – anonymously if desired and if permitted by respective national law – to a compliance hotline that is also accessible to the public. In addition, employees may contact their manager/supervisor, the department head, Law, Patents and Compliance, a Compliance Officer, Internal Audit, or Human Resources. All cases are recorded according to uniform criteria throughout the Bayer Group and managed under the rules outlined in Corporate Policy No. 2029 "Management of Compliance Incidents." [...] Bayer lobbyists will be provided with appropriate training content regarding this code of conduct on responsible lobbying. This training will also be integrated into the onboarding program for Bayer employees in the relevant functions. External lobbyists are obliged to know and comply with the legal specificities in their country of operation but will also need to adhere to this Procedure. Bayer employees, hiring consultants or external representatives, must inform consultants of the standards established in this Procedure. [...] All PASS Heads in the different countries/country groups are responsible for the communication and distribution of this Procedure to the relevant functions. The following implementation measures are mandatory in every county/country group: Communication of the Procedure, Local availability of the Procedure, Onboarding Training.

https://www.bayer.com/sites/default/files/Code%20of%20Conduct%20Dec%202021.pdf

#### Climate Governance

###### Securing Long-term Success and Fostering a High Level of Trust Among All Stakeholders.

###### We have set up a governance system across all divisions to drive climate action forward. Climate action is a cross- function work, where every department in the organization can contribute. By doing this we are moving from commitment towards impact and opportunities. The objective is to leverage these opportunities by benefiting our farmers, patients and consumers, while reducing the risks.

Chitkala Kalidas, Head of ESG

The Chairman of the Board of Management (CEO)
holds direct responsibility for climate protection in his
role as Chief Sustainability Officer. In keeping with their
level of importance, climate-change-related topics and
Bayer's climate strategy are discussed with the Meetings of the Board of Management, the Supervisory
Board and both, the ESG Committee and the Audit
Committee of the Supervisory Board. In addition, the
Sustainability Council that was established in 2020
advises the Board of Management in all matters relai i bili i l di li i

The Board of Management (CEO) is supported in this
by the Public Affairs, Science, Sustainability & HSE
Enabling Function and the sustainability departments
within the divisions. The divisions coordinate the
operational implementation of the climate protection
measures. We have formed Group-wide working
groups for the strategic and operational implementation of climate-change-related activities. [...] #### Collaborate and Engage with Stakeholders

We publicly commit to engaging our stakeholders,
including suppliers, governments, regulators, scientific
societies, trade associations, experts, consumers,

NGOs, and other businesses, toward achieving the
goals of the Paris Agreement. We recognize the
need for collective action across all sectors.

#### Advocating in Line with 1.5°C

###### Excerpt of Net Zero-related memberships and initiatives we are aligning with.

We advocate for a climate position in line with our
ambitious targets and demand that our partners also
undertake action to reduce greenhouse gas emissions
in accordance with the Paris Agreement. We have
therefore published a detailed list of our climate policy
lobbying activities.

In line with our goals, we critically scrutinize our memberships in relevant industry associations and their
positions as regards climate policy measures on a
regular basis. In developing this approach, we have
worked together with Climate Action 100+, an investor
initiative that cooperates with the world's biggest
industrial companies on the issue of climate change.

To ensure maximum transparency in this process,
­Bayer has published the results in the Industry Association Climate Review since 2021. This report compares the climate policy positions of our industry
associations with our own climate goals. As our industry associations represent us in the public
debate, we disclose where we agree with these
positions and where they diverge from ours. Where
differences exist, dialogue enables us to take measures to close these gaps. We disclosed both our
achievements and the challenges that still lie ahead
of us in our Industry Association Climate Review
published in 2023. Bayers Industry Association

Engagement report.

https://www.bayer.com/sites/default/files/bayer-ag-transition-and-transformation-plan-june-2024.pdf

Principles and governance for transparent policy engagement [...] Bayer's advocacy governance aims to provide employee guidance, accountability, oversight, and risk management. Political advocacy spans three divisions Crop Science, Pharmaceuticals and Consumer Health as well as the country organizations. The Global Public Affairs team is part of the Public Affairs, Science, and Sustainability & Health, Safety, and Environment (PASS & HSE) function. The Global Public Affairs Head is a member of the PASS & HSE Leadership Team and leads the Global Public Affairs Leadership Team, which is comprised of the public affairs leads in each of the three divisions and the key markets. Together, they identify key policy priorities and align strategies. Relevant issues and topics for our governmental affairs and political engagement work are regularly reported and discussed directly with the Board of Management. The Head of PASS & HSE provides the Board of Management with a Public Affairs update once per quarter. The Supervisory Board is directly involved in decisions of fundamental importance to the company and confers with the Board of Management on the company's strategic alignment. In addition, the Workers' Council (also represented in the Supervisory Board) receives regular updates on political developments that have significant impact on Bayer. [...] To ensure transparency in our climate policy engagement, we publish an annual overview of our engagement activities on climate policy in addition to this industry association review. This time, we have also disclosed our membership fees for the associations assessed in this report. The membership fee rates are usually set by the respective association and cannot be influenced.

https://www.bayer.com/sites/default/files/Bayer%20Climate%20Review%202023.pdf

#### 2.6 Climate policy engagement and management

Externally, we advocate for a climate position in line with our ambitious targets and demand that our partners also undertake action to reduce greenhouse gas emissions in accordance with the Paris Agreement. We have [therefore published a detailed list of our climate policy lobbying activities](https://www.bayer.com/sites/default/files/2021_Overview_Lobbying-Activities_Climate-Change.pdf)

In line with our goals, we critically scrutinize our memberships in relevant industry associations and their positions as regards climate policy measures on a regular basis. The analysis forms the basis for Bayer's further efforts to advocate for scientifically founded policies to combat climate change through its member [associations. In developing this approach, we have worked together with Climate Action 100+, an investor](https://www.climateaction100.org/) initiative that cooperates with the world's biggest industrial companies on the issue of climate change.

[To ensure maximum transparency in this process, Bayer has published the results in the Industry Association](https://www.bayer.com/sites/default/files/Bayer%20Industry%20Association%20Climate%20Review%202021_0.pdf)
[Climate Review since 2021. This report compares the climate policy positions of our industry associations](https://www.bayer.com/sites/default/files/Bayer%20Industry%20Association%20Climate%20Review%202021_0.pdf)
with our own climate goals. As our industry associations represent us in the public debate, we disclose where we agree with these positions and where they diverge from ours. It is of paramount importance to us that we maintain a dialogue with our associations to achieve a mutually acceptable solution. Where differences exist, dialogue enables us to take measures to close these gaps. We disclosed both our achievements and the [challenges that still lie ahead of us in our Industry Association Climate Review published in 2023.](https://www.bayer.com/sites/default/files/Bayer%20Climate%20Review%202023.pdf)

https://www.bayer.com/sites/default/files/2024-03/bayer-tcfd-report-2023.pdf

**Climate policy engagement and management**\nExternally, we advocate for a climate position in line with our ambitious targets and demand that our partners also undertake decarbonization measures in accordance with the Paris Agreement. We critically scrutinize our memberships in relevant industry associations and their positions as regards climate policy\n[measures. To ensure transparency in this connection, we published an Industry Association Climate Review](https://www.bayer.com/sites/default/files/Bayer%20Industry%20Association%20Climate%20Review%202021.pdf)\nfor the first time in 2021.\n\nThis report compares the climate policy positions of our industry associations with our own climate goals. As\nour industry associations represent us in the public debate, we disclose where we agree with these positions and where they diverge from ours. It is of paramount importance to us that we maintain a dialogue with\nour associations to achieve an amicable solution. Where differences exist, dialogue enables us to take\nmeasures to close these gaps.\n\nThe analysis of 2021 represents a first step and forms the basis for Bayer's further efforts to advocate\nthrough its member associations for scientifically founded policies to combat climate change. In producing\n[this analysis, we worked together with Climate Action 100+, an investor initiative that cooperates with the](https://www.climateaction100.org/)\nworld's biggest industrial companies on the issue of climate change.

https://www.bayer.com/sites/default/files/Bayer-Climate-Program-2021V2.pdf

During the past year, the Council continued the discussion with Bayer on responsible advocacy. In line with [Bayer's Societal Engagement (BASE) Principles, its corporate public affairs / advocacy activities are guided](https://www.bayer.com/en/commitments/our-values) by [Code of Conduct for Responsible Lobbying. Bayer is supporting climate-friendly policies through](https://www.bayer.com/sites/default/files/code-of-conduct-for-responsible-lobbying.pdf) Bayer's industry association membership and has compared the positions of its 63 industry associations [with its own positions in the Industry Association Climate Review 2023. Moreover, transparency is a top](https://www.bayer.com/sites/default/files/Bayer Climate Review 2023.pdf) priority for Bayer. Bayer is committed to build up and strengthen trust by making information accessible from [a whole range of areas including lobbying and political positions (see also Bayer Transparency website).](https://www.bayer.com/en/sustainability/political-principles-and-positions)

https://www.bayer.com/sites/default/files/vds-2024-04-18-sustainability-council-report-2023.pdf

**Climate policy engagement**\n\nExternally, we advocate for a climate position in line with our ambitious targets and demand that our partners also undertake decarbonization measures in accordance with the Paris Agreement. We have therefore\n[published a detailed list of our climate policy lobbying](https://www.bayer.com/sites/default/files/2021_Overview_Lobbying-Activities_Climate-Change.pdf) activities.\n\nIn line with our goals, we critically scrutinize our memberships in relevant industry associations and their\npositions as regards climate policy measures. The analysis forms the basis for Bayer's further efforts to\nadvocate for scientifically founded policies to combat climate change through its member associations.\n[In developing this approach, we have worked together with Climate Action 100+, an investor initiative that](https://www.climateaction100.org/)\ncooperates with the world's biggest industrial companies on the issue of climate change.\n\n[To ensure maximum transparency in this process, Bayer has published the results in the Industry Association](https://www.bayer.com/sites/default/files/Bayer%20Industry%20Association%20Climate%20Review%202021_0.pdf)\n[Climate Review](https://www.bayer.com/sites/default/files/Bayer%20Industry%20Association%20Climate%20Review%202021_0.pdf) since 2021. This report compares the climate policy positions of our industry associations\nwith our own climate goals. As our industry associations represent us in the public debate, we disclose\nwhere we agree with these positions and where they diverge from ours. It is of paramount importance to us\nthat we maintain a dialogue with our associations to achieve an amicable solution. Where differences exist,\ndialogue enables us to take measures to close these gaps. We disclose both our achievements and the\n[challenges that still lie ahead of us in our current Industry Association Climate Review – Engagement Update](https://www.bayer.com/sites/default/files/Bayer_Industry%20Association%20Climate%20Engagement_rg_v05_fin.pdf)\n[2022.](https://www.bayer.com/sites/default/files/Bayer_Industry%20Association%20Climate%20Engagement_rg_v05_fin.pdf)

https://www.bayer.com/sites/default/files/Bayer%20-Climate%20Program%202022.pdf

**Bayer's Societal Engagement (BASE) Principles provide the basics for all our political engagement and shape the way we interact with stakeholders such as legislators, regulators, and civil society organizations. Our 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. Together, both guidelines represent our guiding compass for transparent and fair political engagement and lobbying.** [...] **At Bayer, we go far beyond the statutory requirements of making our political engagement transparent. We publish details of costs, employee numbers, and additional data required by each registry such as in the transparency registers of the European Union, the U.S. Congress, and Germany (published on March 22). In our new dedicated report on political advocacy, we describe our activities, avenues of engagement, as well as disclosures on our expenditures and top advocacy topics in our five largest markets. This report made its debut in 2023 and will be updated annually.** [...] **Given our ambitious climate targets, we annually publish our engagement activities to drive climate-friendly policies. In addition, we regularly examine our memberships in relevant industrial associations and their positions and actions affecting climate policy in accordance with our ambitions. Where we find misalignment between our climate ambitions and those of our industry associations, we take measures to bridge that gap. To disclose our successes and the work that still lies ahead, we annually publish our Industry Association Climate Review.** [...] **Public Affairs is part of the Public Affairs, Science & Sustainability and Health, Safety & Environment function. The Global Public Affairs Leadership Team led by the Global Public Affairs Head and compiled by the public affairs heads of the divisions and key countries develops Public Affairs priorities and strategy and is in charge of talent management. The country officials are responsible for the specific local implementation of political engagement, for being compliance with ethical and legal criteria, and for the creation of transparency.**

https://www.bayer.com/en/sustainability/political-principles-and-positions

**Lobbying** Bayer is committed to transparent lobbying. In line with this, [our Code of Conduct for Responsible Lobbying sets out](https://www.bayer.com/en/sustainability/code-of-conduct-for-responsible-lobbying) binding rules for our involvement in political matters, covers compliance-relevant risks and creates transparency in our interactions with representatives of political institutions. In addition, and based on feedback from various stakeholder groups, we have produced a detailed report on our political advocacy work. As set out in our Code of Conduct for Responsible Lobbying, Bayer as a company expressly prohibits donations to political parties, politicians or candidates for political office. However, as political contributions are protected under US law, local company employees can support individual candidates for parliamentary office at the federal level by making private donations through political action committees (PACs). These voluntary donations are made only by employees, not the company. PACs are separate, segregated funds governed by employees and further regulated by the [US Federal Election Commission (FEC) and some state governments.](https://www.fec.gov/data/committee/C00281162/) Decisions on how these contributions are allocated are made by an independent committee composed of employees. At BAYERPAC, the name of the corresponding committee at Bayer, allocation criteria are applied to reflect societal challenges, among other factors. For example, candidates' positions on issues such as climate change and the protection of biodiversity play an important role here. BAYERPAC also supports candidates from both parties but does not support presidential candidates. These donations are subject to stringent conditions and mandatory transparency measures. The BAYERPAC contributions are regularly re[ported to the FEC. Full details can be viewed on the FEC](https://www.fec.gov/data/committee/C00281162/) website. Bayer employees donated a total of US$289,125 to political candidates at all levels through BAYERPAC in 2024. In other countries, industry associations of which we are a member (such as the German Chemical Industry Association) sometimes make donations on their own responsibility in compliance with the respective statutory regulations, and particularly laws concerning political parties. For Bayer, national liaison offices are key touchpoints between the company and political stakeholders. Where required we publish details of material costs, project expenses, employee numbers and any of the other statistics required in each country according to the respective provisions of the domes[tic transparency register, such as those of the German Parlia-](https://www.lobbyregister.bundestag.de/suche/R002249/27525?backUrl=%2Fsuche%3Fq%3DBayer%2BAG%26pageSize%3D10%26filter%255Bactivelobbyist%255D%255Btrue%255D%3Dtrue%26sort%3DRELEVANCE_DESC) [ment (Bundestag),](https://www.lobbyregister.bundestag.de/suche/R002249/27525?backUrl=%2Fsuche%3Fq%3DBayer%2BAG%26pageSize%3D10%26filter%255Bactivelobbyist%255D%255Btrue%255D%3Dtrue%26sort%3DRELEVANCE_DESC) [European institutions and the US Con-](https://transparency-register.europa.eu/) [gress. We even go beyond statutory requirements by also](https://disclosurespreview.house.gov/?index=%22lobbying-disclosures%22&size=10&sort=%5b%7b%22_score%22:true%7d,%7b%22field%22:%22registrant.name%22,%22order%22:%22asc%22%7d%5d) publishing data for countries and organizational units where – as yet – there is no legal disclosure requirement in our political advocacy transparency report. In 2024, the costs incurred at the liaison offices totaled approximately €2.1 million in Germany; €6.4 million in the European Union; €21.1 million in the United States; €1.2 million in Brazil; and €2.5 million in China.

https://www.bayer.com/sites/default/files/2025-03/bayer-impact-report-2024.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]To ensure transparency in our collaboration with stakeholders and political decision-makers, we proactively publish our global policy positions including on climate policy. Our global climate policy position is in line with our climate commitments, in line with the Paris Agreement and the SBTI.
Sustainability is a core element of our Group Strategy and is the direct responsibility of the Chairman of the Board of Management (BoM). In his role as Chief Sustainability Officer, he is supported by the Public Affairs, Science & Sustainability (PASS) function, which is responsible, inter alia, for the outreach to political stakeholders, the development of sustainability strategies and management systems.
Operational implementation takes place in the divisions and along the value chain. Reviewing and revising regulations and internal audits ensure our management systems are continuously improved and aligned with the respective requirements. The organizational setup guarantees maximum consistency of sustainability commitments and political engagement strategies, both directly and indirectly.
In addition, Bayer critically scrutinize its memberships in relevant industry associations and their positions regarding climate policy measures. To ensure transparency in this connection, we published an Industry Association Climate Review for the first time in 2021. This report compares the climate policy positions of our industry associations with our own climate goals. As our industry associations represent us in the public debate, we disclose where we agree with these positions and where they diverge from ours. It is of paramount importance to us that we maintain a dialogue with our associations to achieve an amicable solution. Where differences exist, dialogue enables us to take measures to close these gaps. An engagement update on the key findings of the Industry Association Climate Review will be published in Q4 2022.
In 2020, Bayer established an independent Sustainability Council (SC) to advise the BoM and the organization in all sustainability matters. The SC comprises internationally recognized experts representing a broad range of expertise, differing geographical origin and different genders. Besides supporting the further development of Bayer's business strategy as regards sustainability, another goal for the SC is to promote cooperation with networks in society, education, industry and politics.

CDP Questionnaire Response 2022

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]To ensure transparency in our collaboration with stakeholders and political decision-makers, we proactively publish our global policy positions including on climate policy. Our global climate policy position is in line with our climate commitments, in line with the Paris Agreement and the SBTI.

CDP Questionnaire Response 2023

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023

Bayer's Industry Association Climate Review 2023 1

I n d u s t r y A s s o c i a t i o n C l i m a te R e v i e w 20 23

Bayer's Industry Association Climate Review 2023 2

I n d u s t r y A s s o c i a t i o n C l i m a t e R e v i e w 2 0 2 3

Contents

Summary findings .................................. 04

Bayer's approach ................................... 06 to climate policy engagement

Approach to industry .............................. 11 association review

Results of alignment review..................... 13

Climate policy engagement .................... 18 in industry associations

Next steps ............................................. 23

Appendix ............................................... 24

Bayer's Industry Association Climate Review 2023

D r i v i n g c l i m ate a c t i o n to g e t h e r

Dear stakeholder,

The extreme weather events of recent years or the increasing water scarcity have never made the importance of tackling the climate crisis even clearer. Whether it is delivering on the goals of the Paris Agreement or realizing the benefits of a move to a net zero economy, greater progress is vital.

Bayer is committed to playing its part. Contributing to the wider change needs to go beyond our company and bring others with us. Trust and transparency underpin this process. Thus, transparency remains a cornerstone of Bayer's values. This agenda is no exception. Disclosure fosters dialogue and supports accountability. This report is just one way in which we are contributing to transparency in our climate action but also in our policy advocacy.

This review provides an update on Bayer's climate advocacy activity in our trade association engagement. It sets out how we continue to promote climate-positive policies and how we are trying to find practical ways to support the delivery of the Paris Agreement by engaging and working in partnership with associations across markets.

As a leader in life sciences, we contribute to a future that is healthier for humans and the planet. We continue to work hard towards our target of becoming climate neutral by 2030 by our own operations and achieving net zero GHG emissions by 2050. While this transformation was never going to be simple, it is more important than it has ever been.

For this reason, our focus on ensuring trade association alignment with and in support of the Paris Agreement remains a key aspect of Bayer's overall public affairs agenda. I am pleased to see progress being made, set out in the report that follows since we performed our first comprehensive review in 2021.

There is a clear move to greater support of climate-friendly policies in our associations. We also see a significant decrease in mission positions indicating an incipient debate in the associations and ensuring progress in establishing an understanding of the significance of climate change as a material issue across key sectors. An additional eight associations are no longer classed as 'misaligned' with Bayer's climate policy criteria that are in line with the Paris Agreement.

Team Bayer has played a great role across relevant markets in contributing to these changes and collaborating with associations and trade bodies to make progress on the complex policy questions we

3

need to collectively resolve. We are also sharing more details here on the nature of our relationships with industry associations.

But in turn, there is still more to be done. We will continue to build on the foundations we have been putting in place. Bayer remains the only company in the life sciences sector committed to this form of process. Growing our engagement with healthcare associations across our largest markets therefore remains important. Emphasis placed on the agricultural sector in turn also remains important, in building on the capacity in place to address the key questions the net zero transition raises for this sector.

Policy engagement is a key aspect of becoming climate-neutral. Navigating the complexities of the transition to a healthier planet means tackling volatility head-on. From disruption in the global energy markets following Russia's invasion of Ukraine to the growing impacts of extreme weather, our agility in response is matched by a continued focus on the long-term.

Relationships with our wider stakeholder community are as important as the changes we make across our own company. It's only by acting together, in collaboration with others, that we will be able to overcome and reach beyond the volatility and uncertainty climate change entails. This work has never been more important.

We will continue to work with purpose and resolve with our industry association partners in taking steps towards a net zero future.

Yours sincerely,

Matthias Berninger Head Public Affairs, Science, Sustainability and HSE

Bayer's Industry Association Climate Review 2023 4

S u m m a r y f i n d i n g s

After our first Industry Association Climate Review in 2021, this year's review is the first time we have been able to draw a comparison over time. In 2023, 63 associations have been assessed overall, with 12 associations excluded from the review process and 10 additions made (see page 12 for more detail).

Bayer's association relationships on climate policy

// 36% overall improvement in instances of full alignment across associations assessed. Equivalent to an improvement across 67 specific policy topics.

// 80% decrease in missing position on key policy issues, meaning associations assessed are clearer on Paris Agreement alignment on 82 separate policy topics.

// 8 fewer instances of overall material misalignment.

// 2 instances of material misalignment requiring intensified engagement until escalation as outlined in the engagement process (see page 18 for more detail).

We would like to highlight the positive trend in the U.S. Chamber of Commerce and the Associated Chambers of Commerce and Industry of India, whose respective positions have evolved from a material misalignment to a partial misalignment with Bayer's climate positions. In addition, we identified a move from a material misaligned to an aligned position on promoting technologies and innovation that improve climate performance by Unión Industrial Argentina. We outlined our engagement activities in the respective associations in our Engagement Update 2022.

Industr y association climate policy assessments over time

14% increase

77

72

36% increase

317 2021

10

235

186

26% decrease

Aligned Partial Misalignment

No position Misaligned

2023 253

2

80% decrease

Bayer's Industry Association Climate Review 2023

Bayer's assocation engagement on climate policy

Bayer is dedicated to a climate policy that is in harmony with our ambitious climate targets. To ensure transparency in our climate policy engagement, we regularly publish our activities in two different disclosure initiatives on our website.

The Industry Association Climate Review focuses on our engagement undertaken with around 60 industry associations, in supporting alignment with policy goals of the Paris Agreement. In each report, we also include examples of our positions on legislative actions as well as collaborations with industry association partners in supporting the transition to net zero, such as the following ones in this report: Working to ensure robust standards on the issue of EU carbon removal certification.

Engaging to ensure the consideration of carbon farming in the EU certification scheme.

Capturing the opportunity around sustainable product design and levers for change with Multinacionales con España.

Initiated collaboration across one of India's most significant business groups - the Confederation of Indian Industry (CII) – by establishing a Task Force on Sustainable Agriculture to ensure the long-term sustainability of Indian agriculture.

5

In addition, we also disclose our membership fees of the associations assessed in this review for the first time.

Apart from our engagement with industry associations, we provide annual overviews of our own engagement activities on climate policy in the United States, Brazil, China, and Germany as these are our largest markets, as well as on the EU and international levels.

Alignment categorization

Categorizations of alignment with Bayer's positions on relevant climate-related policy:

Aligned

Partial misaligned

Misaligned

No position

Industry association is fully aligned with Bayer's climate position on the appropriate issue.

Industry association does not fully match Bayer's position or commitment on the appropriate issue; improvements pursued via engagement.

Industry association oppose Bayer's position or commitment on the appropriate issue; process of escalation begins (staring with engagement and then potential remediation).

Industry association has no position at all on the appropriate issue, which Bayer views as room for improvement and an opportunity for change via engagement.

Bayer's Industry Association Climate Review 2023 6

B a y e r 's a p p r o a c h t o c l i m a t e p o l i c y e n g a g e m e n t

Our climate position

As a science-based company, Bayer has recognized the risks posed by global climate change. We aim to continuously reduce greenhouse gas (GHG) emissions within our company and along our entire value chain in accordance with the United Nations' Sustainable Development Goals and the Paris Agreement to limit global warming to 1.5°C above pre-industrial levels.

We are dedicated to supporting and enabling a climate policy that is in harmony with our ambitious climate targets and therefore advocate for decarbonization measures in line with meeting the goals of the Paris Agreement. This means we seek to support regulatory frameworks and policy initiatives that both promote innovative low-carbon and carbon-neutral products, processes, value chains, and business models and strengthen renewable energy and industry competitiveness. Given our commitment, we publish our direct engagement activities on climate policy on our website next to our engagement in industry associations as outlined in this report.

Bayer's initiative-specific climate policy positions and engagement activities around the globe are guided by our climate commitments and Global Climate Policy Position (see below). In addition, we would like to supplement the specific policy position examples on recent climate-related legislative initiatives from the 2022 Engagement Update with more recent examples that are outlined on page 20.

Bayer has ambitious climate targets to meet the goals of the Paris Agreement

BInadyuesrt'rsyInAdsussotcriyatAiosnsoCcliiamtiaotne CRleimvieawte Review 2023 77

B ay e r 's G l o b a l

C l i m ate P o l i c y P o s i t i o n

(as of May 2023)

Bayer supports regulatory frameworks and policy initiatives that both promote innovative low carbon and carbon neutral products, processes, value chains, and business models and strengthen industry competitiveness.

To this end:

// It is crucial to maintain the openness of innovative ideas and to

support new technologies. The transformation to carbon neutrality catalyzes the development of a range of new technologies, business models, and operational practices in industry and agriculture. It is our conviction that innovation for climate mitigation and adaption should be inclusive of all promising technologies. Openness as supported by a diversity of tools and methods and careful consideration of individual trade-offs and synergies that relate to specific local environments strengthens resilient networks.

// A successful transformation requires an integrated consideration of social, environmental, and economic needs. Decisions on the

use of a technology for mitigation should be based on an integrated analysis of social, environmental, and economic risks and benefits. Social acceptance is essential and prerequisite to secure both social inclusion and competitiveness future prosperity.

// Climate neutrality should be embedded into both industry and

agriculture policy strategies to transform into a climate-neutral and sustainable economy while preserving competitiveness at the ame time. Action plans to establish additional incentive mechanisms for good practices supporting GHG emission reduction targets in industry and agriculture are widely and globally necessary. Country-based measures always need to be in line with WTO framework and further international agreements.

// Renewable energies are the basis for climate-neutral production.

Climate neutrality will be achieved to a large extent by switching from fossil fuels to renewable energies. To foster the energy transition, governments need to ensure cost competitive alternatives to fossil fuels, to guarantee supply security of renewable energies, and to ensure the availability of adequate systems for purchasing renewable energies.

BInadyuesrt'rsyInAdsussotcriyatAiosnsoCcliiamtiaotne CRleimvieawte Review 2023 88

// In agriculture, a certification to a recognized standard is key so that farmers will be able to quantify, verify, certify, and sell their

GHG emission savings as carbon credits to industries willing to offset their carbon footprint. Pricing for these high-quality offsets should be appropriate to outweigh the implementation, verification, and certification costs ensuring the return on investment for farmers.

// We recognize that land-use change is one of the biggest contributors to GHG emissions in agriculture and must be limited to preserve

biodiversity and avoid carbon emissions. We strongly encourage public and private sector investments in innovations that support sustainable intensification of food production and advocate for policies and foster market mechanisms that enable such innovations to provide opportunities for ecosystem diversity improvements and carbon removals due to the reduced land footprint of agriculture.

// Digital enables a more sustainable manner of farming. New digital

applications should be accepted as tools that mitigate climate change in farming. Given its potential, digital farming should be a priority of government's strategic plans and reflected in agricultural policymaking. Preconditions for the success of digital technologies in farming include robust data access and privacy policies, rural connectivity, agriculture, and environmental regulations incorporating the capabilities of digital technologies.

Bayer's Industry Association Climate Review 2023

Principles and governance for transparent policy engagement

Bayer Societal Engagement (BASE) Principles provide the basis for all our external engagement and shape the way we interact with stakeholders such as legislators, regulators, and civil society organizations. Our 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. Together, both guidelines represent our guiding compass for transparent and fair political engagement and lobbying.

Transparency is a key priority for Bayer. We are committed to building and strengthening trust by making information accessible from a whole range of areas. Therefore, we are about to publish our first Advocacy Transparency Report where we outline our principles, governance, strategies, and priorities, and spending on Bayer's policy engagement and political advocacy. Further information on our political engagement is published on our website and in our Sustainability Report 2023.

Bayer's advocacy governance aims to provide employee guidance, accountability, oversight, and risk management. Political advocacy spans three divisions Crop Science, Pharmaceuticals and Consumer Health as well as the country organizations. The Global Public Affairs team is part of the Public Affairs, Science, and Sustainability & Health, Safety, and Environment (PASS & HSE) function. The Global Public Affairs Head is a member of the PASS & HSE Leadership Team and leads the Global Public Affairs Leadership Team, which is comprised of the public affairs leads in each of the three divisions and the key markets. Together, they identify key policy priorities and align strategies. Relevant issues and topics for our governmental affairs and political engagement work are regularly reported and discussed directly with the Board of Management. The Head of PASS & HSE provides the Board of Management with a Public Affairs update once per quarter. The Supervisory Board is directly involved in decisions of fundamental importance to the company and confers with the Board of Management on the company's strategic alignment. In addition, the Workers' Council (also represented in the Supervisory Board) receives regular updates on political developments that have significant impact on Bayer.

9

Bayer's Industry Association Climate Review 2023 10

To ensure transparency in our climate policy engagement, we publish an annual overview of our engagement activities on climate policy in addition to this industry association review. This time, we have also disclosed our membership fees for the associations assessed in this report. The membership fee rates are usually set by the respective association and cannot be influenced.

Industr y association membership fees

Membership fees in 2022 (EUR)

>1M

500,000 - <1M

100,000 - <500,000

50,000 - <100,000

<50,000

Industry associations

// CropLife Europe

// CropLife International

// Pharmaceutical Research and Manufacturers of America

// Association of the British Pharmaceutical Industry

// Cefic

// Efpia

// Agrofarma

// Biotechnology Innovation Organization

// Bundesverband der Deutschen Industrie

// Consumer Healthcare Products Australia

// CropLife Australia

// CropLife Canada

// Brazilian Association of the Chemistry Industry

// Food, Health & Consumer Products of Canada

// Japan Pharmaceutical Manufacturers Association

// AmCham China

// AmCham Mexico

// Argentine Business Council for Sustainable Development

// Assobiotec

// Association of Enterprises with Foreign Investment

// Brazilian Business Council for Sustainable Development

// BusinessEurope

// Canada Grains Council

// CESPEDES

// China-Brazil Business Council

// Confederation of British Industry

// Confederation of Indian Industry

// AAPRESID

No direct fees // Agriculture Biotechnology Council

// AmCham Argentina

// Verband forschender Arzneimittelhersteller

// Verband der Chemischen Industrie

// Industrieverband Agrar

// Phyteis

// US Chamber of Commerce

// Federchimica

// France Chimie

// Global Self-Care Federation

// Medicines Australia

// PAGB

// SINDUSFARMA

// CropLife America

// EU Chamber of Commerce in China

// Federation of Indian Chambers of Commerce and Industry

// Forética

// Indian Chemical Council

// Industrial Union Argentina

// Mexican-German Commerce Chamber

// National Confederation of Industry

// The Associated Chambers of Commerce and Industry of India

// Union Française des Semenciers

Bayer's Industry Association Climate Review 2023 11

A p p r o a c h t o i n d u s t r y a s s o c i a t i o n r e v i e w

Adjusted policy criteria for this review

Our climate commitments and, thus, our global climate policy position remain valid. Thus, the policy criteria from the 2021 Review were used as the basis for evaluation of the industry associations. A small adjustment to the criteria on carbon offsetting and natural climate solutions was made. Use of carbon offsetting and natural climate solutions to mitigate climate change Specifically, we changed "to deliver net zero" to "mitigate climate change" as we now support the use of carbon offsets and natural climate solutions only to mitigate climate change, no longer to deliver net zero.

Two key criteria were used to gauge the scope for alignment, with related sub-criteria for consideration: i) Explicitly publicly support alignment with the Paris Agreement (or not), covering: // The Paris Agreement and meeting its goals.

// The transition to achieving net zero emissions, including an interim target.

// Policies that enable the transition to net zero Organizations were assessed based on needing to demonstrate a positive and public advocacy position on each of the above. ii) Does not contravene relevant policies that Bayer has on: // Lowering GHG emissions per kg of harvested produce in major agricultural markets by 30% by 2030.

// Promoting technologies and innovation that improve climate performance, including energy efficiency.

// Sourcing 100% of procured electricity from renewable sources of energy by 2030.

// Support for market-based approaches to carbon pricing and trading.

// Acknowledgment of climate-related trade measures within the rules-based international trade system.

// Use of carbon offsetting and natural climate solutions to mitigate climate change.

Industry association selection

Selection of relevant membership bodies for inclusion was based on one or more of the following criteria as in our first review in 2021: // The organization in question is active in Bayer's biggest markets, as determined by related company metrics, for example sales revenue, number of employees in market or scope 1 and 2 emissions footprint.

// The association is active in a country with significant GHG emissions for Bayer, regardless of the scale of Bayer's presence in that market.

// It is a notable industry group working internationally. Some associations are not limited to a single geographical entity, and it would be remiss of us not to include those in our assessment.

The respective industry associations in turn: // Engage in or contribute to the climate change discussion; or // Undertake direct advocacy/lobbying engagement on climate-related policy; or // Has a public policy position on climate change; or // Could reasonably be expected to have a position on climate-related policy given the nature of its work.

To strengthen the climate policy discussion across many sectors, we have started to include a greater number of healthcare industry associations for our largest markets, namely the US, China, Brazil, and Germany as well as the EU and the international level. Overall, we have included eight new industry associations as outlined in the visualization.

Bayer's Industry Association Climate Review 2023 12

Industr y associations included in the review

Denmark

CPFaornoodadu,dcHatseaoltfhC&anCaodnasumer DDCaaonnniifssehhdeCArgraortipicounPltrouofrteeDc&atnioFisnohoAdInssdCouocsuitanrytcioiln

CropLife Canada Finland

UBCCSihrooatpmeLcbihfeenroAolmofgCeyroicImnanmoevracteion OrgaCnainzaatdioanGrains Council UPHACPAAKhgsAsoessaranGioorclftBmeccuhdiilTaaateucettriirceooaeuhntnitBoIiooncnioffadotBtluehfIrscneiBtthdriBrsinuiethrosisisttliohrsyghInydCuesntrtyre ItICTAFnahimondlennyuCfiCssehthhdrayeemInmrFadeFitcuidionasenltlarrainoetdfsion

aPnhdarMmaancuefuatcictaulreRressoefaArcmherica new GBDeuerunmtdseacshnveeynrbInadndusdtreier FAAesgdsrooefbracirohmtimeacica

MAMemexxCiicchaaonm-GMeermxiacno Commerce Chamber IVCnehdreubmsatnir-idsecvdheeerrbnaInndduAsgtrraier SFpoaréintica

CESPEDES new PVehrabramnadundteerrnfoerhsmcheenndneenw France

France Chimie Brazil Phyteis (formerly UIPP)

National Confederation of Industry Union Française des Semenciers China-Brazil Business Council new

SBAsIuNssDoincUeiaSstsFioACnRooMufnAtchilenfeCowrhSemusistatrinyaIbndleuDsteryvelopment InFodefdCiaeormatmioenrcoefIannddiaInndCuhsatmrybers

Confederation of Indian Industry Associated Chambers of International Commerce and Industry of India CMIGWnrltaoooenrbprlundaLfaliaBftSeciuoetIsunnlifrant-eeClerrFssanesraaedCtnieoFdorneauAadtnilseocsrnilaootocifofiaSnPtuihonsanetraswminaancbeelweutDiceavlelopment AfAAArogmrArgPeSCeRnnuhEtsatintSimaneIiDnaABarubgsleeinnDteisnesaveCloopumnceinlt Indian Chemical Council

Industrial Union Argentina

EU

Business Europe Cefic CropLife Europe Efpia new

China

EU Chamber of Commerce in China AmCham China Association of Enterprises with Foreign Investment new R&D Based Pharmaceutical Association Committee of China

Japan

Japan Pharmaceutical Manufacturers Association

Australia

CropLife Australia Australian Seed Federation Consumer Healthcare Products Australia Medicines Australia new

New Zealand

Animal and Plant Health NZ (formerly AgCarm)

In addition to the US National Association of Manufacturers, from which we have already tendered in 2022 (see Industry Association Climate Review – Engagement Update 2022), we have further excluded the following 11 associations from this year's review for various reasons: // AmCham Brazil, AmCham Germany, Digital Europe, the Australian Food and Grocery Council, Mexico's National Employers Confederation, and India's Research and Information System for Developing Countries as it has turned out that these associations are not decisive for Bayer's climate policy activities; // Coalizão Brasil Clima, Florestas e Agricultura and UN Global PAC Brazil as we intend to focus on associations where we can create a bigger impact; // The Polish Association for Sustainable Agriculture and the Polish-German Chamber of Commerce for current resource reasons on site; // The Russian Union of Industrialists and Entrepreneurs as Bayer has withdrawn any active participation due to the ongoing invasion of Russia in Ukraine while remaining a member of the association. Consequently, Bayer cannot verify or engage in climate-related positions. We are currently evaluating our memberships considering the current political situation in Russia.

Methodology

Based on the developed approach led by a project team comprising Bayer public affairs and sustainability professionals outlined in the first Industry Association Climate Review 2021, the whole assessment was conducted by an external consultant to ensure an independent analysis. Multi-source content was gathered and considered in this process, covering material from across association websites, media articles, social media, and public statements from the bodies' principal executives. Research teams undertook desktop research, seeking a comprehensive picture of positions adopted by associations in their relevant territories. A central team then reviewed the findings to ensure consistency. Categorizations of alignment with Bayer's positions on relevant climate-related policy are outlined on pages 15 to 17.

The project is supervised at the most senior levels of the organization by Bayer's Global Public Affairs Leadership Team including approval for final actions. The project sponsor is Matthias Berninger, Head Global Public Affairs, Science and Sustainability & Health, Safety and Environment who is leading both public affairs and sustainability strategies and implementation actions.

Bayer's Industry Association Climate Review 2023

R e s u l t s o f a l i g n m e n t r e v i e w

There has been a clear overall improvement in instances of full alignment across the associations assessed. This is now 36% higher, with 66 additional instances of policy alignment across the positions assessed. This is matched by a consequential and significant 80% fall in the number of instances of 'no position'. Associations are increasingly developing policy positions where previously they were absent.

Bayer is contributing to this positive trend across markets in our day-to-day interactions with industry associations, alongside the engagement process set out on page 18. In addition to initiatives by individual actors, however, the larger political and economic context has also developed in favor of more climate-friendly policies, as climate change becomes an increasingly important and practical area of focus across wider sectors of the economy.

A partial increase in associations achieving just 'partial alignment' across key topics is also clear. An increase of six instances represents a 7% increase overall. While potentially counterintuitive, this still represents progress, as associations move through the policy development process (with most previously having been classed as 'no position'). Bayer would expect and will actively encourage these policy positions to evolve to support limiting global warming to 1.5°C and supporting the net zero transition.

The significant moves seen in 'endorsement of the Paris Agreement' and 'promotion of the transition to net zero' can be explained as two key foundational aspects of the transition. We are still pleased to see changes made on more specific topics such as 'lowering GHG emissions of agriculture' role of 'natural climate solutions to mitigate climate change'. As the transition continues to be navigated globally – growing in complexity while societally we experience the growing impacts of already unavoidable climate change – the importance of navigating detailed and more niche policy issues will continue to grow.

13

There are notable changes in alignment across a range of policy positions assessed:

Aligned

Partial misaligned

No position

Misaligned

2021 total 2023 total Difference

186 252 66

72 78 6

317 235 -82

10 2 -8

Significantly, there are eight fewer instances of overall material misalignment, namely at the US Chamber of Commerce, Associated Chambers of Commerce and Industry of India (ASSOCHAM), and the Unión Industrial Argentina (UIA). However, these also included the US National Association of Manufacturers and Russian Union of Industrialists & Entrepreneurs (RSPP) which are not included in this year's review.

Two instances are still evident concerning the policy stance of Industrieverband Agrar (IVA) in Germany and Unión Industrial Argentina (UIA). Detail on Bayer's response can be found on page 18, in line with our longstanding engagement and escalation process.

Bayer's Industry Association Climate Review 2023 14

Changes across each policy position between 2021 and 2023

Endorse the Paris Agreement

Promote the transition to Net Zero

Promote policies to enable Net Zero

Lower GHG emissions in agriculture by 30%

Promote technologies & innovation to improve climate performance

Source 100% of electricity from renewables by 2030

Market-based approaches to carbon pricing & trading

2021

2023

Change

2021

2023

Change

2021

2023

Change

2021

2023

Change

2021

2023

Change

2021

2023

Change

2021

2023

Change

Acknowledge climate-related trade measures within rules-based trade system

Carbon offsetting & natural climate solutions to mitigate climate change

2021

2023

Change

2021

2023

Change

Aligned Partial misaligned Misaligned No position

23 9 0 33

30 13 0 20

7 4 0 -13

14 17 3 31

28 19 0 16

14 2 -3 -15

24 13 2 26

35 11 0 17

11 -2 -2 -9

19 7 1 38

23 6 1 33

4 -1 0 -5

43 3 1 18

50 4 0 9

7 1 -1 -9

14 15 2 34

20 13 1 29

6 -2 -1 -5

19 5 0 41

22 5 0 36

3 0 0 -5

9 1 1 54

16 2 0 45

7 1 -1 -9

21 2 0 42

29 4 0 30

8 2 0 -12

Bayer's Industry Association Climate Review 2023 15

Complete industry association assessments

A summary of the full industry association assessment across all relevant criteria is set out below. More details on instances of material and partial misalignment are also provided in the Appendix.

Territory Paris Agreement

Transition to net zero

Policies to enable net zero

AAPRESID Argentina

Agcarm New Zealand ZeNaelawnd

Agicultural Biotechnology Council ABC

United Kingdom

Agrofarma Italy

AmCham Argentina Argentina

AmCham China

AmCham Finland

AmCham Mexico

Assobiotec

Associação Brasileira da Indústria Química (ABIQUIM)

Association of British HealthTech Industries (ABHI)

Association of Enterprises with Foreign Investment

Association of the British Pharmaceutical Industry (ABPI)

China

Finland

Mexico

Italy

Brazil

United Kingdom

China

United Kingdom

AFeudsetrraaltiaionnSeed Australia

Biotechnology Innovation Organization

Brazil-China Business Council

Brazilian Business Council for Sustainable Development (CEBDS)

Bundesverband der Deutschen Industrie (BDI)

Business Europe

United States

Brazil

Brazil

Germany

European Union

Canada Grains Council Canada

CEFIC EuUronpioenan

Aligned Partial misaligned Misaligned No position

Lower GHG emissions in agriculture by 30%

Promote technologies & innovation to improve climate performance

Source 100% of electricity from renewables by 2030

Market-based approaches to carbon pricing & trading

Acknowledge climate-related trade measures within rules-based trade system

Carbon offsetting & natural climate solutions to deliver net zero

Bayer's Industry Association Climate Review 2023

Territory Paris Agreement

CESPEDES

Confederation of British Industry

Mexico

United Kingdom

CDaonnifsehdeInradtuiostnryof Denmark

Confederation of Finnish Industries

Confederation of Indian Industry (CII)

Consejo Empresario Argentino para el desarrollo sostenible / Argentine Business Council for Sustainable Development (CEADS)

Consumer Healthcare Products Australia

CropLife America

CropLife Australia

CropLife Canada

Finland

India

Argentina

Australia

United States

Australia

Canada

CropLife Europe EuUronpioenan

Croplife International International

DFoaondishCoAugnrcicilulture & Denmark

DAsasnoischiaCtiroonp Protection Denmark

Efpia EuUronpioenan

CEUomCmhaemrcbeeirnoCfhina China

Federation of oInfdCiaonmCmhearmcebearnsd India

Industry (FICCI)

Federchimica

Food, Health & Consumer Products of Canada (FHCP)

Italy

Canada

Forética Spain

France Chimie France

Global Self-Care Federation

Indian Chemical Council

International

India

Transition to net zero

Policies to enable net zero

16

Aligned Partial misaligned Misaligned No position

Lower GHG emissions in agriculture by 30%

Promote technologies & innovation to improve climate performance

Source 100% of electricity from renewables by 2030

Market-based approaches to carbon pricing & trading

Acknowledge climate-related trade measures within rules-based trade system

Carbon offsetting & natural climate solutions to deliver net zero

Bayer's Industry Association Climate Review 2023

Territory Paris Agreement

INDUSTRIEVERBAND AGRAR (IVA)

International Federation of Pharmaceutical Manufacturers and Associations (IFPMA)

Japan Pharmaceutical Manufacturers Association (JPMA)

Medicines Australia

Mexican-German Commerce Chamber (CAMEXA)

National Confederation of Industry (CNI)

PAGB - the Consumer Healthcare Association

Pharmaceutical Research and Manufacturers of America (PhRMA)

Phyteis (formerly Union des Industries de la Protection des Plantes or UIPP)

RDPAC

Sindicato da Indústria de Produtos Farmacêuticos (SINDUSFARMA)

The Associated Chambers of Commerce and Industry of India (ASSOCHAM)

Germany

International

Japan

Australia

Mexico

Brazil

United Kingdom

United States

France

China

Brazil

India

TFehdeeCrahteiomnic–aFliInnldaunsdtry Finland

Union Francaise des Semenciers - UFS (seed association)

Union Industrial Argentina (UIA)

France

Argentina

US Chamber of Commerce

Verband der Chemischen Industrie (VCI)

Verband forschender Arzneimittelhersteller (VFA)

World Business Council of Sustainable Development

United States

Germany

Germany

International

Transition to net zero

Policies to enable net zero

17

Aligned Partial misaligned Misaligned No position

Lower GHG emissions in agriculture by 30%

Promote technologies & innovation to improve climate performance

Source 100% of electricity from renewables by 2030

Market-based approaches to carbon pricing & trading

Acknowledge climate-related trade measures within rules-based trade system

Carbon offsetting & natural climate solutions to deliver net zero

Bayer's Industry Association Climate Review 2023 18

C l i m a t e p o l i c y e n g a g e m e n t i n i n d u s t r y a s s o c i a t i o n s

Engagement process

Bayer continues to act on the findings raised in this analysis. Priority will be placed on engaging those industry associations highlighted as materially misaligned, but we will also be addressing instances of partial misalignment and no positions. In our Engagement Update published in 2022, we have outlined our engagement steps and challenges for the material misalignments identified in the 2021 review. In addition, we have also exemplary illustrated our increased scope of activities to raise awareness for climate policy in other associations.

We remain committed to the engagement process divided into two phases, which is explained in detail in the 2021 Review. Engagement comes first, as Bayer raises the relevant issue with our trade association and seeks an amicable resolution. We expect that this process proves sufficient in the majority – if not all – instances of misalignment within one year after publication. Where necessary, however, we will move to remediation. Marking an escalation of the process, this would see Bayer exert pressure to influence the association's lobbying position. We will be working hard to leverage our influence to secure a change in policy position; however, such a situation could ultimately result in Bayer leaving the organization in question.

We are fully prepared to do what is required to secure the best outcome but believe that exerting influence from inside will ultimately have a greater positive impact than ending a relationship with an association.

Addressing material misalignments with associations identified in the review

In our 2021 Industry Association Climate Review we identified a total of 10 material misalignments in positions of our associations connected to six different associations. In 2022, we outlined the progress we have seen in the Engagement Update. Overall, we saw either a change in the respective association or assessed that we can make a greater impact on their position by further engaging rather than leaving the association – an observation confirmed by this year's review. While two of the identified associations, the National Association of Manufacturers, U.S., and the Russian Union of Industrialists & Entrepreneurs were no longer included in this year's review as outlined on page 12, only two of the identified material misalignments remain.

We would like to highlight the U.S. Chamber of Commerce and the Associated Chambers of Commerce and Industry of India, whose respective positions have evolved from a material misalignment to a partial misalignment with Bayer's climate positions. In addition, we identified a move from a material misaligned to an aligned position on promoting technologies and innovation that improve climate performance by Unión Industrial Argentina.

Besides the overall positive trend towards a more climate-friendly policy positioning across the reviewed associations, we have two remaining material misaligned positions. As the former material misalignments have proven that we can make a greater impact on their position by further engaging rather than leaving the association, we have decided to remain in the two associations for the time being. However, according to our engagement and remediation process, we will take different actions as detailed below.

Bayer's Industry Association Climate Review 2023 19

// Policy criteria: 100% of procured electricity from renewable energies

Unión Industrial Argentina (UIA), Argentina

Bayer's planned action

The public position of the UIA remains unchanged. Although we see support for moving towards wider use of renewable energy in conversations, this movement is not gaining traction due to the continuing difficult economic situation of the country that heavily impacts the industry. However, since we have seen a positive development in the other misaligned position of the UIA, Bayer will continue to engage in regular meetings for climate policy in line with our climate targets to secure 100% renewable energies.

Association's position development in 2022 update

The public position of the UIA remains unchanged. Nevertheless, there is support for moving towards wider use of renewable energy in conversations. Due to the overall economic situation of the country that heavily impacts industry, however, this movement is not gaining traction.

Material misalignment in 2021 review

Association position:

The UIA supports the use of all energy sources available in Argentina's territory, including hydrocarbons alongside renewables. It suggests the economic and environmental feasibility of its production and use should be taken into account.

Bayer's engagement

Bayer engages in regular meetings with the UIA and will continue to engage for climate policy and to foster climate-friendly business models.

Bayer position:

Do not contravene relevant policies that Bayer has on sourcing 100% of procured electricity from renewable energies by 2030.

We are committed to reducing our Scope 1 & 2 emissions by 42% by the end of 2029 compared to our 2019 baseline. Part of our approach requires a switch to 100% renewable energies and supporting climate-neutral technologies. We do not support ongoing investment in hydrocarbons.

// Policy criteria: 30% reduction in GHG emissions per kg of harvested produce

Industrieverband Agrar (IVA), Germany

Bayer's planned action

Given the still existing lack of publicly declared acknowledgment of the urgent need to reduce GHS emissions at the IVA, we have recently initiated a very targeted discussion based on the review results at the highest levels of the association and use corresponding best practice examples, for example from CropLife Europe. In addition to this, we are currently discussing internal remediation measures such as a reduction of our membership fees. In any case, we are still very pleased if more companies in the agricultural sector would join a critical review of the association's climate positions.

Association's position development in 2022 update

There is still a lack of publicly declared acknowledgment of the urgent need to reduce GHS emissions at the IVA. The association focuses on climate action driven by increasing the efficiency of existing infrastructure.

Material misalignment in 2021 review

Association position:

IVA advocates that intensive agriculture produces fewer emissions per grain in comparison to organic farming. This does not acknowledge that regardless of process, there is an urgent need to reduce GHG emissions from all forms of farming.

Bayer's engagement

Bayer is collaborating and engaging with the IVA in various dialogues to advance more proactive communication in leading the way forward for the agriculture sector. Since Bayer is the first company to review climate lobbying efforts of associations in the agriculture sector, we welcome support in this initiative to jointly drive change.

Bayer position:

Do not contravene relevant policies that Bayer has on lowering GHG emissions per kg of harvested produce in major agricultural markets by 30%. We want to help reduce GHG emissions in major agricultural markets – per kilogram of crop yield – by 30% by 2030. This includes Bayer helping farmers to use climate-friendly methods, such as reducing ploughing and using digital solutions to reduce CO2 emissions.

Bayer's Industry Association Climate Review 2023 20

Examples of advocating for climate-friendly policies in industry associations

"Multinacionales con España" creates an extensive plan to promote green products

As part of the "Multinacionales con España" association, Bayer collaborates with Spanish institutions to tackle some of society's most pressing sustainability issues. The latest initiative that Bayer supported through this association is called "Ecodesign and Business", a report containing a multitude of proposals to promote the design of all products with sustainability in mind, or "ecodesign".

Among the proposals is to incentivize climate awareness in product design with fiscal measures like tax incentives, new collaboration avenues between the public and private sectors, and uniform standards to measure product sustainability performance. In the report, Bayer also serves as an example of good sustainability practice, an additional way in which Bayer is aiming to set and improve the industry standard.

Confederation of Indian Industry (CII) to work on emission reduction in agriculture

CII is a membership association aiming to pivot the engagement of various industry sectors in the direction of India's national development. As one of the most important associations in India with over 9000 members from the public and private sectors, the CII must balance the diverse viewpoints of its wide range of members. In this context, Bayer successfully initiated a collaboration with all relevant stakeholders to develop a CII Task Force on Sustainable Agriculture. To ensure the long-term sustainability of Indian agriculture, the Bayer-initiated Agriculture Committee developed comprehensive targets that were successfully met in 2022 and are set to be further continued and enhanced in 2023. Among others, the Sustainable Agriculture Task Force is collaborating with industry partners and experts to identify efficient technologies for emission reduction and improved water management. Additionally, the Task Force is launching an industry-led pilot project to maximize the impact of sustainable practices in rice production, especially in terms of water conservation.

Bayer's Industry Association Climate Review 2023

EU discussion on carbon removals in the VCI, Germany

As the national chemical industry association, the VCI represents the interests of German chemical companies and German subsidiaries of foreign enterprises, representing over 90% of the German chemical industry. Against the background of the current EU discussion on a certification scheme for carbon removals, the VCI has also developed a position on carbon removal and the EU legislative initiative with its member companies. In these discussions, Bayer was intensively engaged given the strategic importance of carbon removals for our climate strategy as well as for the agricultural sector. Despite many discussions at expert level as well as in the highest climate committee, the VCI position differs significantly from ours, which is why we have decided to differentiate ourselves from the VCI on this specific issue.

We essentially differ in this: while the VCI is advocating for consideration of industrial CCU without permanency requirements under the carbon removal framework, Bayer is advocating for maintaining the mitigation hierarchy and keeping the removal framework of the EU focused on technical and nature-based removal solutions. As part of nature-based solutions, Bayer is focusing its advocacy engagement on the consideration of carbon farming in the EU certification scheme (see our position on the next page).

Additionally, we generally advocate for maintaining the mitigation hierarchy. It also follows that we define carbon capture at source as emission reduction; therefore, carbon recycling should not be considered under a carbon removal scheme as requested by the VCI. It should only be considered as a reduction if the usage after capture ensures permanency. Bayer is reducing its emissions along a 1.5°C pathway and using offsetting only for the emissions beyond this reduction pathway. In the end removals should only be used to compensate for hard to reduce emissions or emissions that cannot be reduced. As the EU-ETS is based on a reduction pathway, it should not be eligible for removal certificates at this stage as this would violate the mitigation hierarchy. The same applies to policy discussions on CCU and CCS, which should be regulated separately from a carbon removal certification scheme since these should be considered as emission reductions.

21

Bayer's position on the European Commission legislative proposal for a Regulation establishing a Union certification framework for carbon removals (as of May 2023)

Bayer welcomes the regulation proposal that provides a solid starting point for an EU harmonized voluntary certification framework. We believe carbon removals are important to mitigate climate change, but we want to stress that climate mitigation first and foremost must be realized through GHG emission reduction. Carbon removals should only be used to balance GHG emissions that cannot be or are hard to reduce. In the long run, they should contribute to reversing climate change.

Our contribution to this proposal focuses on arable carbon farming (the growth of annual crops such as wheat, potato, oil seed rape etc. on arable land) on mineral soils and includes the below features. We published our detailed position on an European carbon removal certification scheme here.

// Create certification of GHG emission reduction:

We share the opinion that a certification framework is important to guarantee the quality of removals. Climate mitigation, however, covers carbon removals and GHG emission reductions. To assess the quality of a climate mitigation effort, certification of both is needed. In the case of carbon farming, GHG emission reduction and carbon removal often go hand in hand. Many carbon farming practices reduce GHG emissions and contribute to removing carbon. Being able to prove both through certification would support the climate mitigation effort required.

// Provide guidance on the use of carbon removals:

To reach the Paris goal of staying below 1.5°C, GHG emissions should be reduced along a strict 1.5°C pathway. Carbon removals should only be used as an additional measure to GHG emission reduction to accelerate climate mitigation.

// Separate carbon removals from biogenic carbon

emissions: In the proposal, emission reductions should not be confused with carbon removals. For carbon farming on mineral soils, only net increases in removals should be certified. Emission reduction from a biogenic carbon pool could be considered a co-benefit.

// Ensure proper capacity building: Bayer agrees to

the importance to support individual farmers with the necessary technical advice to effectively remove carbon. However, this should not only be the responsibility of producers, but also of other legal entities representing operators and certification bodies.

Bayer's Industry Association Climate Review 2023 22

// Strengthen the efficacy of the voluntary framework:

The Regulation will create a voluntary framework that is not yet linked to any mandatory regime on carbon accounting such as EU ETS, Effort Sharing Regulation, LULUCF Regulation, or other. While Bayer supports a stronger 'compliance' link, we understand the policy decision to create a voluntary space to gain experience before deciding on a compliance system. The Regulation means to create an open, horizontal, and decentralized governance structure. We appreciate the experimental space for further development of carbon farming and the appropriate certification this voluntary framework creates.

// Ensure simplicity of baseline setting in carbon

farming: Bayer supports a harmonized, standardized baseline, as it offers opportunities to reward front runners while incentivizing ones behind to catch up. An even more practical approach could be a flat standardized baseline for carbon farming on arable mineral soils. Under a flat baseline, all net increases in soil carbon are certifiable in principle. The benefits of a flat baseline will be reduced transaction costs and stronger incentives for operators to engage in certified removal activities.

// Facilitate long-term carbon storage in farming:

Bayer appreciates the proposal of the Commission to ensure long-term storage. Considering the carbon removed released again after the ending of the monitoring period could however disincentivize investments in carbon removals. To enable project longevity, we propose the possibility to extend the monitoring period the inclusiveness of carbon removal portfolio-wide permanence mechanisms.

// Include social and economic sustainability

objectives: Carbon farming can and should serve more sustainability objectives than climate mitigation. Important co-benefits to include are farm productivity, security of agricultural production, quality of agricultural produce, and farmers' economic return to ensure farming remains an attractive sector to work in.

// Develop an outcome-based carbon removal

certification framework: Farming practices that can contribute to carbon removals or the generation of co-benefits do not necessarily do so. Their performance greatly depends on field implementation and other conditions. An outcome-based system provides the best guarantee that farmers can deliver on outcomes.

Bayer's Industry Association Climate Review 2023

N e x t s t e p s

This updated assessment of Bayer's industry association climate alignment highlights important progress. However, it also shows there is more still to do. Building on engagement initiated over the past two years, we will continue to focus on areas where Bayer can achieve an outsized impact.

This includes a focus on conversations with associations where there is still a lack of positions on key climate policy issues. The emphasis we have placed on engaging agricultural sector organizations has coincided with a broader appreciation of its importance in terms of climate change mitigation, resilience, and adaptation. This remains important work.

23

In parallel, climate change is a big threat to global public health. As previously stated, we will also focus on greater breadth and depth, in working with health and life sciences groups, in building on understanding, dialogue, and sophistication in their interaction with the climate-related policy agenda.

Bayer remains committed to actively advocating for policies that support the delivery of the Paris Agreement and demonstrating transparency in the process. We will publish an Engagement Update next year, covering among other topics, action taken in addressing areas of misalignment and refocusing wider engagement. This will be followed by another comprehensive assessment in 2025.

Bayer's Industry Association Climate Review 2023 24

A p p e n d i x

Instances of material misalignment

Below is detail on each instance of material misalignment, ordered by policy criteria, identified during the assessment process. Each organization is now the focus of the engagement process. Where relevant this will lead to Bayer pursuing remediation options as outlined on page 18.

// Policy criteria: 30% reduction in GHG emissions per kg of harvested produce

Industry association: Industrieverband Agrar (IVA) Country: Germany

Policy criteria

Do not contravene relevant policies that Bayer has on lowering GHG emissions per kg of harvested produce in major agricultural markets by 30%.

Association position

IVA advocates that intensive agriculture produces less emissions per grain in comparison to organic farming. In so doing, IVA failed to make clear the urgent need to reduce GHG emissions from all forms of farming, regardless of type.

Source: https://www.iva.de/umwelt/klimaschutz

Bayer position

We want to help reduce GHG emissions in major agricultural markets – per kilogram of crop yield – by 30% by 2030.

This includes Bayer helping farmers to use climate friendly methods, such as reducing ploughing and using digital solutions to reduce CO2 emissions.

// Policy criteria: 100% of procured electricity from renewable energy sources

Industry association: Unión Industrial Argentina (UIA) Country: Argentina

Policy criteria

Do not contravene relevant policies that Bayer has on sourcing 100% of procured electricity from renewable energy by 2030.

Association position

The UIA supports the increased, large-scale exploitation of the Vaca Muerta shale formation so that it can continue to be a significant source of fossil fuel energy for the country. It is the world's second largest shale gas reserve and fourth largest shale oil reserve. The UIA also supports extracted gas to be shared with neighboring countries like Chile and Bolivia.

Source: https://www.uia.org.ar/energia/3377/seminario-de-la-uia-sobre-eficiencia-energetica/

Bayer position

We are committed to reducing our Scope 1 & 2 emissions by 42% by the end of 2029 compared to our 2019 baseline. Part of our approach requires a switch to 100% renewable energies and supporting climate-neutral technologies. We do not support ongoing investment in hydrocarbons.

Bayer's Industry Association Climate Review 2023 25

Instances of partial misalignment

Below is an overview of each instance of partial misalignment, ordered by policy, that were identified during the assessment process. Each organization is now the focus of the engagement process (see page 18). Given the number of organizations in question it is impracticable and somewhat duplicative to disclose additional context on the specific instance of partial misalignment.

This is available on request depending on the stakeholder in question. Should engagement prove unsuccessful, further detail will also be disclosed as Bayer pursues the remediation process.

// Policy criteria: Publicly suppor t the Paris Agreement and its goals

Bayer position

We are dedicated to a climate policy that is in harmony with our ambitious climate targets and therefore advocate for decarbonization measures in line with the Paris Agreement.

Partially misaligned industry associations

Agrofarm

AmCham Mexico

Assobiotec

Association of British HealthTech Industries (ABHI)

CESPEDES

Consejo Empresario Argentino para el desarrollo sostenible / Argentine Business Council for Sustainable Development (CEADS)

CropLife America

CropLife Australia

CropLife Europe

France Chimie

Indian Chemical Council

Union Industrial Argentina (UIA)

Verband forschender Arzneimittelhersteller (VFA)

Country

Italy

Mexico

Italy

United Kingdom

Mexico

Argentina

United States

Australia

European Union

France

India

Argentina

Germany

Bayer's Industry Association Climate Review 2023 26

// Policy criteria: Publicly suppor t the transition to net zero

Bayer position

A science-based approach to combating climate change recommends the transition to net zero emissions by 2050. We have set ourselves the target to achieve net zero GHG emissions including our entire value chain by 2050 or sooner and signed the Business Ambition for 1.5°C. In line with its own positions, Bayer expects industry associations to engage for the transition to net zero.

Partially misaligned industry associations Country

AmCham China China

Assiobiotec

Associação Brasileira da Indústria Química (ABIQUIM)

Brazil-China Business Council

Consejo Empresario Argentino para el desarrollo sostenible / Argentine Business Council for Sustainable Development (CEADS)

CropLife America

CropLife Australia

Italy

Brazil

Brazil

Argentina

United States

Australia

Croplife International International

EU Chamber of Commerce in China China

France Chimie France

Indian Chemical Council India

Industrieverband Agrar (IVA) Germany

Japan Pharmaceutical Manufacturers Association (JPMA) Japan

Mexican-German Commerce Chamber (CAMEXA) Mexico

National Confederation of Industry (CNI) Brazil

Phyteis (formerly Union des Industries de la Protection des Plantes or UIPP) France

Union Industrial Argentina (UIA) Argentina

US Chamber of Commerce United States

Verband der Chemischen Industrie (VCI) Germany

Bayer's Industry Association Climate Review 2023 27

// Policy criteria: Publicly suppor t policies that enable the transition to net zero

Bayer position

We are dedicated to a climate policy that is in harmony with our ambitious climate targets and therefore advocate for decarbonization measures in line with the Paris Agreement. The net zero transformation catalyzes the development of new technologies, business models and operational practices in industry and agriculture. Innovation for climate mitigation and adaption should be inclusive towards all promising technologies. Bayer supports regulatory frameworks and policy initiatives that promote innovative low carbon and carbon neutral products, processes and business models and strengthen industry competitiveness at the same time.

Partially misaligned industry associations Country

AmCham China China

AmCham Mexico Mexico

Associação Brasileira da Indústria Química (ABIQUIM) Brazil

Canada Grains Council Canada

CESPEDES Mexico

Croplife International International

France Chimie France

Japan Pharmaceutical Manufacturers Association (JPMA) Japan

Mexican-German Commerce Chamber (CAMEXA) Mexico

PAGB - the Consumer Healthcare Association United Kingdom

Union Industrial Argentina (UIA) Argentina

// Policy criteria: Do not contravene relevant policies that Bayer has on lowering GHG emissions per kg of harvested produce in major agricultural markets by 30%.

Bayer position

Bayer is working with farmers to reduce the ecological footprint of agriculture, which currently accounts for about 25% of GHG emissions worldwide. We want to help reduce GHG emissions in major agricultural markets – per kilogram of crop yield – by 30% by 2030. This applies to the most emitting cropping systems in regions Bayer operates. This includes Bayer helping farmers to use climate-friendly methods, such as reducing ploughing and using digital solutions, to reduce CO2 emissions.

Partially misaligned industry associations Country

AmCham China China

AmCham Mexico Mexico

Brazilian Business Council for Sustainable Development (CEBDS) Brazil

Canada Grains Council Canada

CropLife America United States

Federchimica Italy

Bayer's Industry Association Climate Review 2023 28

// Policy criteria: Do not contravene relevant policies that Bayer has on promoting technologies and innovation that improve climate performance, including energy efficiency.

Bayer position

The net zero transformation catalyzes the development of new technologies, business models and operational practices in industry and agriculture. Innovation for climate mitigation and adaption should be inclusive towards all promising technologies. Bayer supports regulatory frameworks and policy initiatives that promote innovative low carbon and carbon neutral products, processes and business models and strengthen industry competitiveness at the same time.

Partially misaligned industry associations

Associação Brasileira da Indústria Química (ABIQUIM)

Australian Seed Federation

CESPEDES

Consejo Empresario Argentino para el desarrollo sostenible / Argentine Business Council for Sustainable Development (CEADS)

Country

Brazil

Australia

Mexico

Argentina

// Policy criteria: Do not contravene relevant policies that Bayer has on sourcing 100% of procured electricity from renewable energies by 2030.

Bayer position

We will reduce our Scope 1 & 2 emissions by 42% until end of 2029 compared to our 2019 baseline. This target has been approved by the Science Based Target initiative as aligned with a 1.5°C pathway. To accomplish this, we will combine measures, such as more efficient inward and outward ventilation systems, a move to climate-neutral technologies, such as geothermal energy for heating and cooling and a switch to 100% purchased electricity from renewable sources.

Renewable energies are the basis for climate-neutral production. Climate neutrality will be achieved to a large extent by switching from fossil fuels to renewable energies. To foster the energy transition, governments need to ensure cost competitive alternatives to fossil fuels, to guarantee security of supply of renewable energies and to ensure the availability of adequate systems for purchasing renewable energies.

Partially misaligned industry associations Country

AmCham Mexico Mexico

Associação Brasileira da Indústria Química (ABIQUIM) Brazil

Brazilian Business Council for Sustainable Development (CEBDS) Brazil

CEFIC European Union

EU Chamber of Commerce in China China

Federation of Indian Chambers of Commerce and Industry (FICCI) India

Federchimica Italy

Forética Spain

Mexican-German Commerce Chamber (CAMEXA) Mexico

National Confederation of Industry (CNI) Brazil

The Associated Chambers of Commerce and Industry of India (ASSOCHAM) India

US Chamber of Commerce United States

Verband forschender Arzneimittelhersteller (VFA) Germany

Bayer's Industry Association Climate Review 2023 29

// Policy criteria: Do not contravene relevant policies that Bayer has on suppor t for a market-based approaches to carbon pricing and trading.

Bayer position

A carbon price mechanism is a key regulatory instrument. Market-based approaches like cap and trading systems are highly efficient to foster the development of carbon-low or carbon-neutral technologies and products without predefining technologies. Sector-specific features need to be recognized (no one size fits all-approach). Given the need for carbon neutrality steps across the globe, Bayer supports a global carbon market – at least at a G20 level. If this is not applicable, regional carbon pricing mechanisms with installed carbon leakage protection are preferable to national ones in any case. Internally, we align our capex spending with our ambition to achieve net zero GHG emissions by 2050, in line with the global goal to limit global warming to 1.5°C. To drive internal change, we have set ourselves an internal carbon price of €100 per metric ton when calculating our capital expenditure projects and additionally conduct ecological assessments of relevant investments.

Partially misaligned industry associations Country

Assobiotec Italy

EU Chamber of Commerce in China China

Indian Chemical Council India

Japan Pharmaceutical Manufacturers Association (JPMA) Japan

Verband der Chemischen Industrie (VCI) Germany

// Policy criteria: Do not contravene relevant policies that Bayer has on acknowledgment of climate-related trade measures within the rules-based international trade system.

Bayer position

Climate neutrality should be embedded into both industry and agriculture policy strategies to transform to a climate-neutral and sustainable economy while preserving competitiveness at the same time. Action plans to establish additional incentive mechanisms for good practices supporting GHG emission reduction targets in industry and agriculture are widely and globally necessary. Bayer favours rule-based free trade, thus, country-based measures always need to be in line with WTO framework and further international agreements.

Partially misaligned industry associations Country

Brazilian Business Council for Sustainable Development (CEBDS) Brazil

EU Chamber of Commerce in China China

// Policy criteria: Do not contravene relevant policies that Bayer has on carbon offsetting & natural climate solutions to mitigate net zero.

Bayer position

In agriculture, a certification to a recognized standard is key so that farmers will be able to quantify, verify, certify and sell their GHG emission savings as carbon credits to industries willing to offset their carbon footprint. Pricing for these high-quality offsets should be appropriate to outweigh the implementation, verification and certification costs ensuring the return for investment for farmers. We strongly encourage public and private sector investments in innovations that support sustainable intensification of food production and advocate for policies and foster market mechanism that enable such innovations to provide opportunities for ecosystem diversity improvements and carbon removals due to the reduced land footprint of agriculture.

Partially misaligned industry associations Country

AmCham Finland Finland

CropLife Australia Australia

Federchimica Italy

Food, Health & Consumer Products of Canada (FHCP) Canada

Bayer's Industry Association Climate Review 2023 30

Published by

Bayer AG, 51368 Leverkusen, Germany

Date of publication

October 2023

Public Affairs, Science, Sustainability & HSE

Kai Mornhinweg, kai.mornhinweg@bayer.com

Bayer on the internet: www.bayer.com

Forward-Looking Statements

This publication may contain forward-looking statements based on current assumptions and forecasts made by Bayer management. Various known and unknown risks, uncertainties and other factors could lead to material differences between the actual future results, financial situation, development or performance of the company and the estimates given here. These factors include those discussed in Bayer's public reports which are available on the Bayer website at www.bayer.com. The company assumes no liability whatsoever to update these forward-looking statements or to conform them to future events or developments.

www.bayer.com

Engagement/Advocacy Report