Trelleborg AB

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Trelleborg AB provides a high level of detail on the climate-related regulations it seeks to influence, naming the EU tyre-labelling regulation (Regulation (EU) 2020/740) and a suite of UN ECE type-approval rules for passenger-car, truck, motorcycle and agricultural tyres. It is equally clear about how it exerts influence: through its membership of the European Tyre & Rubber Manufacturers’ Association (ETRMA), which, according to the Association, “is involved in continuous dialogue with EU and international institutions, national agencies and other industry sectors” and focuses on “representing, communicating and promoting the industry to policymakers, as well as providing technical advice for its members.” These descriptions reveal multiple mechanisms—dialogue, formal representation and the provision of technical advice—and identify the targets of those efforts (EU and international institutions and national agencies). The company’s policy stance is more general: it states that its engagement is “aligned with the Paris Agreement” and that it offers “Support with no exceptions” for the named regulations, but it does not spell out any concrete amendments, quantitative targets or other specific outcomes it is trying to secure. Overall, the disclosures demonstrate strong transparency on the policies covered and the ways the company lobbies, while offering only broad indications of the results it hopes to achieve.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Trelleborg provides only limited insight into how it governs climate-related lobbying. It states that it has "a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement" and adds that it "ensure[s] that our engagement activities are consistent with our overall climate change strategy by using well-established processes and mechanisms for reporting and planning of key sustainability and climate-related projects", indicating a declared intention to align external engagement with its climate targets. Yet none of the accompanying governance descriptions specify how lobbying activities are reviewed or approved, nor do they describe any procedure for checking trade-association positions or other indirect advocacy. While the Audit Committee is mandated to "monitor the Group’s work with sustainability issues", this remit is framed around sustainability reporting and risk management rather than policy advocacy, and there is no mention of a dedicated individual or committee that oversees lobbying alignment. Consequently, the company discloses a general commitment to align engagement with the Paris Agreement but does not reveal concrete structures, oversight responsibilities or monitoring processes for its direct or indirect lobbying.	1