BorgWarner Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	BorgWarner’s Corporate Governance Committee Charter provides for the board committee to “assist our Board in fulfilling its oversight responsibility by: … Overseeing the Company’s sustainability strategy, policies, and procedures, including corporate responsibility matters,” but the charter does not reference oversight of lobbying or policy engagement. Meanwhile, BorgWarner’s Government Affairs department “oversees lobbying activities, communications with public officials, and memberships with trade associations and other tax-exempt organizations,” and the department “reviews each membership annually to ensure ongoing alignment between the industry and trade organizations and BorgWarner’s Beliefs and vision of a clean, energy-efficient world,” illustrating a formal mechanism for indirect lobbying oversight. The team also “ensures lobbying compliance through a third-party verification process,” reflecting structured monitoring of its advocacy. Furthermore, BorgWarner states that “we communicate our company’s position on emerging sustainability and climate change-related topics, and in doing so are able to assess alignment of the trade associations with which we engage,” indicating active management of association positions to support its planned science-based target. However, we found no evidence of any policy or process to align direct lobbying with its climate objectives, and the company explicitly confirms it does not hold “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” The company does not disclose a named individual charged with climate lobbying alignment or describe how its direct policy advocacy is monitored for consistency with its climate strategy. View Sources	C

Overall Assessment

Analysis

Score

Moderate

BorgWarner’s Corporate Governance Committee Charter provides for the board committee to “assist our Board in fulfilling its oversight responsibility by: … Overseeing the Company’s sustainability strategy, policies, and procedures, including corporate responsibility matters,” but the charter does not reference oversight of lobbying or policy engagement. Meanwhile, BorgWarner’s Government Affairs department “oversees lobbying activities, communications with public officials, and memberships with trade associations and other tax-exempt organizations,” and the department “reviews each membership annually to ensure ongoing alignment between the industry and trade organizations and BorgWarner’s Beliefs and vision of a clean, energy-efficient world,” illustrating a formal mechanism for indirect lobbying oversight. The team also “ensures lobbying compliance through a third-party verification process,” reflecting structured monitoring of its advocacy. Furthermore, BorgWarner states that “we communicate our company’s position on emerging sustainability and climate change-related topics, and in doing so are able to assess alignment of the trade associations with which we engage,” indicating active management of association positions to support its planned science-based target. However, we found no evidence of any policy or process to align direct lobbying with its climate objectives, and the company explicitly confirms it does not hold “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” The company does not disclose a named individual charged with climate lobbying alignment or describe how its direct policy advocacy is monitored for consistency with its climate strategy.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	BorgWarner’s disclosure centres on its participation in the U.S. Department of Energy’s Better Climate Challenge and its own emission-reduction goals, but it offers no information about any attempts to influence public policy. It does not identify a single climate-related law, regulation or legislative proposal it has engaged on, describes no channels such as meetings, submissions or industry-association advocacy, and sets out no governmental outcomes it hopes to secure. The material therefore provides no evidence of climate-policy lobbying activity or the transparency such lobbying would require.	E