BayWa AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	BayWa AG has established an internal governance process to align its direct engagement activities with its climate change strategy through coordination between its Public Affairs and Corporate Sustainability functions. As the company states, “a regular meeting (once a month) has been established between Public Affairs and the team of Corporate Sustainability, responsible for the climate strategy,” and within these sessions, “current legislation proposals and BayWa's engagement activities are discussed” to ensure alignment. Public Affairs “proactively involves sustainability coordinators within the entire BayWa Group to receive insights and information about climate-related targets and interests,” and both departments “are linked to other entities worldwide in regular meetings” to share updates on legislative developments and the progress of the climate strategy. However, the company does not disclose any governance process for indirect lobbying through trade or industry associations, and it provides no named individual or formal committee tasked with overseeing the alignment of its lobbying with its climate objectives. The company also confirms it has “no public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” and it does not plan to adopt one in the next two years, suggesting that it lacks an explicit public-facing alignment framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

BayWa AG has established an internal governance process to align its direct engagement activities with its climate change strategy through coordination between its Public Affairs and Corporate Sustainability functions. As the company states, “a regular meeting (once a month) has been established between Public Affairs and the team of Corporate Sustainability, responsible for the climate strategy,” and within these sessions, “current legislation proposals and BayWa's engagement activities are discussed” to ensure alignment. Public Affairs “proactively involves sustainability coordinators within the entire BayWa Group to receive insights and information about climate-related targets and interests,” and both departments “are linked to other entities worldwide in regular meetings” to share updates on legislative developments and the progress of the climate strategy. However, the company does not disclose any governance process for indirect lobbying through trade or industry associations, and it provides no named individual or formal committee tasked with overseeing the alignment of its lobbying with its climate objectives. The company also confirms it has “no public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” and it does not plan to adopt one in the next two years, suggesting that it lacks an explicit public-facing alignment framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	BayWa AG provides a high level of transparency around its climate-related lobbying. It names several concrete measures it has engaged on, including the EU regulation on deforestation-free products, the EU Directive on corporate sustainability due diligence, and support for Eco-Scheme rules to include Agri-PV areas under the CAP, as well as positions put forward during Germany’s 2021 federal coalition negotiations. The company also explains how it seeks to influence these files, saying it has “met directly with policymakers of the European Commission to communicate the challenges for trading companies” and that it participated in formal consultations and “exchange with decision-makers,” thereby disclosing both direct meetings and written submissions as its main channels and identifying the European Commission as the principal target. Finally, it is explicit about the outcomes it pursues: it supports the deforestation-free products regulation but asks that soy need not be traced “back to the plot level” and that “mass balance” be excluded, advocates that “Agri-PV areas are to be included in CAP direct payments,” and proposes amendments to German renewable-energy regulation. By detailing the specific laws, the means of engagement and the concrete amendments it seeks, the company demonstrates strong overall transparency on its climate lobbying activities.	B