Spirit AeroSystems Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Spirit AeroSystems provides only limited transparency around its climate-related lobbying. It identifies one concrete policy engagement—the Kansas Aviation Tax Credit program intended to grow the state’s aerospace workforce—but does not name any other climate or sustainability-focused laws or regulations it has sought to influence. The company merely states that it “engages with government officials at federal, state, and local levels” and works through industry associations, without clarifying whether this involves meetings, written submissions, coalition letters, or other specific channels, nor does it specify which agencies or legislators are targeted. On intended outcomes, Spirit AeroSystems links its support of the tax credit to workforce expansion and broadly endorses the aviation industry’s net-zero-by-2050 ambition, yet it offers no concrete policy changes, timelines, or quantitative objectives it is pursuing through its advocacy. Taken together, the disclosures reveal only a single identifiable policy and provide little insight into lobbying methods or desired policy outcomes.	1

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Spirit AeroSystems describes a clear process for aligning its indirect lobbying through trade associations with its climate strategy, stating that “prior to entering into new affiliations or expanding the scope of current affiliations, an organization’s policy positions are among the several factors that we would consider,” that through “membership and participation, we would be able to monitor whether their activities are consistent with our climate and energy strategy,” and that the company “utilizes our disclosures to the CDP Climate Change program as an opportunity to further review and assess whether the public policy positions of trade associations for which Spirit AeroSystems has an affiliation are consistent with our own climate change strategy.” While these steps represent a concrete mechanism for monitoring and aligning indirect engagement, the company does not disclose how it governs or aligns its direct lobbying activities nor does it identify any individual or formal body responsible for overseeing lobbying alignment.	2