BASF SE – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	BASF presents a notably comprehensive system to keep its climate-related advocacy in line with its own strategy and the Paris goals. The company explains that BASF assures global alignment of its advocacy work and its activities in associations via established governance processes and internal networks that apply to all regions, and that these processes are codified in its Policy on Political Relations and Advocacy and Policy on Political Association Management, which oblige employees to monitor the associations activities and trigger action if there is a significant contradiction between the associations advocacy goals and the values, principles and strategy of BASF. Oversight is clearly anchored at the highest level: the Corporate Communications & Government Relations unit reports directly to the Chairman of the Board of Executive Directors, while The Board of Directors decides on BASF's climate change strategies and the heads of the Corporate Development unit and the Net Zero Accelerator project report to the Board to ensure consistency of actions. The company describes concrete mechanisms for both direct and indirect lobbying: it engages directly with policymakers in all key markets under transparent guidelines and our publicly stated positions, and, for trade bodies, it regularly review[s] the positions and activities on climate and energy policies of our major associations and publish[es] our findings on the internet, increasing engagement to change an associations stance or, if necessary, the membership may be terminated. BASF also makes public an Industry Associations Review [that] compares the energy and climate protection positions of BASF and the most important associations, providing an explicit, published assessment of alignment. These disclosures, combined with the stated escalation steps (If advocating against BASFs key interests cannot be prevented the membership may be terminated or we publicly state that BASF has a diverging view) indicate an end-to-end governance framework covering monitoring, escalation, public reporting and board-level oversight, demonstrating strong transparency and accountability around both direct and indirect climate-lobbying activities. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

BASF presents a notably comprehensive system to keep its climate-related advocacy in line with its own strategy and the Paris goals. The company explains that BASF assures global alignment of its advocacy work and its activities in associations via established governance processes and internal networks that apply to all regions, and that these processes are codified in its Policy on Political Relations and Advocacy and Policy on Political Association Management, which oblige employees to monitor the associations activities and trigger action if there is a significant contradiction between the associations advocacy goals and the values, principles and strategy of BASF. Oversight is clearly anchored at the highest level: the Corporate Communications & Government Relations unit reports directly to the Chairman of the Board of Executive Directors, while The Board of Directors decides on BASF's climate change strategies and the heads of the Corporate Development unit and the Net Zero Accelerator project report to the Board to ensure consistency of actions. The company describes concrete mechanisms for both direct and indirect lobbying: it engages directly with policymakers in all key markets under transparent guidelines and our publicly stated positions, and, for trade bodies, it regularly review[s] the positions and activities on climate and energy policies of our major associations and publish[es] our findings on the internet, increasing engagement to change an associations stance or, if necessary, the membership may be terminated. BASF also makes public an Industry Associations Review [that] compares the energy and climate protection positions of BASF and the most important associations, providing an explicit, published assessment of alignment. These disclosures, combined with the stated escalation steps (If advocating against BASFs key interests cannot be prevented the membership may be terminated or we publicly state that BASF has a diverging view) indicate an end-to-end governance framework covering monitoring, escalation, public reporting and board-level oversight, demonstrating strong transparency and accountability around both direct and indirect climate-lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	BASF discloses climate-policy lobbying in a highly granular manner. It names multiple identifiable measures it engages on, including the EU Emissions Trading System, the revision of the EU Renewable Energy Directive, the planned Carbon Border Adjustment Mechanism, the EU Battery Regulation, the reform of Germany’s Renewable Energy Sources Act and a European Hydrogen Strategy, as well as proposals such as Contracts for Difference for hard-to-abate sectors and the revision of the Industrial Emissions Directive. The company is equally explicit about how it tries to influence these files, describing “publicly available contribution to EU consultation,” “direct meetings with MEPs, Governments, and European Commission,” invitations of “MEPs and state representatives to site visits,” hosting events in its Brussels office, sharing analyses with “the EU Commission and national authorities,” and participation in hearings of the Landtag Rheinland-Pfalz and alliances such as the EU Clean Hydrogen Alliance and BusinessEurope—thereby identifying both the mechanisms and the specific policymaking targets. BASF also sets out concrete objectives for each engagement: it seeks “proper carbon leakage protection both for direct and indirect emissions” through continued free allocation under the EU ETS, calls for subsidy-free investment conditions and cross-border trading in the Renewable Energy Directive revision, supports carbon-footprint and recycled-content requirements in the Battery Regulation while requesting clear due-diligence guidance, advocates Contracts for Difference and expanded ETS Innovation Fund volumes, and opposes the current CBAM design because of “administrative burdens” and impact on value chains. By providing detailed positions, named policies, and clearly described channels and interlocutors, BASF demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	A