Volvo AB – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Volvo AB discloses a coherent framework that governs both its own advocacy and its participation in trade associations, indicating strong oversight from the top of the organisation. The company states that "the dialogue is guided by yearly priorities approved by the Executive Board" and that its advocacy is "based on guiding principles In line with the Paris Climate Agreement", demonstrating that climate-related objectives are built into its direct lobbying mandate. For indirect lobbying, it has "developed a new governance model, including regular assessments, escalation structure and communication" and confirms that "during 2021 we performed an assessment of trade associations in relation to our positions on climate change and energy transition", covering 14 (later 21) associations across key markets. Each membership "has a responsible Volvo Group contact person" and any misalignment triggers a process in which "the first step is to initiate a dialogue with the trade association In case where a trade association would deviate significantly from Volvo Groups positions, we will evaluate whether to end our membership." The outcome of these reviews is escalated, as "the governance model and the outcome of the assessment has been reported to the Volvo Group Executive Board", and memberships are "evaluated yearly and confirmed that they are not working against the Paris Climate Agreement". This evidence shows regular monitoring, defined escalation, and Board-level oversight for both direct and indirect lobbying, signalling strong governance. However, the company has not disclosed a detailed lobbying-alignment report or an external assurance of its assessments for 4 years, since 2021, and it provides limited information on how it systematically reviews the alignment of its own direct lobbying activities beyond setting annual priorities. View Sources	B

Overall Assessment

Analysis

Score

Strong

Volvo AB discloses a coherent framework that governs both its own advocacy and its participation in trade associations, indicating strong oversight from the top of the organisation. The company states that "the dialogue is guided by yearly priorities approved by the Executive Board" and that its advocacy is "based on guiding principles In line with the Paris Climate Agreement", demonstrating that climate-related objectives are built into its direct lobbying mandate. For indirect lobbying, it has "developed a new governance model, including regular assessments, escalation structure and communication" and confirms that "during 2021 we performed an assessment of trade associations in relation to our positions on climate change and energy transition", covering 14 (later 21) associations across key markets. Each membership "has a responsible Volvo Group contact person" and any misalignment triggers a process in which "the first step is to initiate a dialogue with the trade association In case where a trade association would deviate significantly from Volvo Groups positions, we will evaluate whether to end our membership." The outcome of these reviews is escalated, as "the governance model and the outcome of the assessment has been reported to the Volvo Group Executive Board", and memberships are "evaluated yearly and confirmed that they are not working against the Paris Climate Agreement". This evidence shows regular monitoring, defined escalation, and Board-level oversight for both direct and indirect lobbying, signalling strong governance. However, the company has not disclosed a detailed lobbying-alignment report or an external assurance of its assessments for 4 years, since 2021, and it provides limited information on how it systematically reviews the alignment of its own direct lobbying activities beyond setting annual priorities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Volvo Group provides a comprehensive overview of its climate lobbying activities, detailing the mechanisms, specific policies, and outcomes it seeks. It explains that it engages in “direct and indirect advocacy related to public policy, mainly in the EU and the US,” maintains registrations in the EU Transparency Register and the Lobby Register of the USA, and participates actively in trade associations to shape proposed regulations. The company also identifies its audiences, noting that it has “worked directly with lawmakers, manufacturers, environmental NGOs, medical and health organizations, environmental entrepreneurs, and other stakeholder groups” to advance Senate Bill 410 (the Powering Up Californians Act). It has named several distinct climate regulations it has lobbied: the Euro VII proposal for new pollutant emission standards for trucks and buses, the EU CO2 emissions regulation, and the US EPA GHG standards. Finally, Volvo Group clearly sets out the outcomes it seeks, advocating for the removal of “regulatory obstacles that have hindered the effective expansion of electric vehicle charging infrastructure,” for frameworks encouraging investor-owned utilities to prioritize charging infrastructure aligned with zero-emission goals, and for incentive programs for vehicles and infrastructure to support electrification. It also calls for accelerated fleet renewal and massive investment in electrification to accelerate the net-zero transition. This breadth and depth of disclosure demonstrate a comprehensive level of transparency around its climate lobbying.	A