Boston Scientific Corp

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Boston Scientific provides a highly transparent account of its climate-related lobbying. It names several identifiable policies it has engaged on, including Minnesota’s renewable portfolio standard and associated goal of “10 % solar electricity generation by 2030,” the Irish Government’s “Climate Action Plan” to reach carbon neutrality by 2050, and state proposals in Massachusetts covering “net metering caps,” “energy efficiency” legislation and a prospective “carbon tax,” as well as federal advocacy for cap-and-trade and carbon pricing. The company is equally clear about how and where it lobbies. It describes direct outreach through its “Government Affairs department in Washington, DC that lobbies federal policymakers on issues that are related to climate change,” testimony to the “Oireachtas Committee on Environment and Climate Action,” partnership work with the State of Minnesota, engagement with Massachusetts policymakers, participation in consultations on Ireland’s Climate Action Plan, and indirect work through trade groups such as the American Chamber of Commerce Ireland, eHeat Ireland, the National Association of Manufacturers and the U.S. Chamber of Commerce. By identifying these mechanisms and the specific governmental bodies targeted, the company demonstrates detailed disclosure of its lobbying channels. Boston Scientific also makes its objectives explicit. It seeks to help Minnesota reach its 10 % solar goal, to “lift the net metering cap” in Massachusetts, to secure “increased support for clean energy generation and energy efficiency” and nationwide “cap and trade and carbon tax solutions,” and has provided “recommendations for effective implementation of measures to support the transition to electrified industrial heating in Ireland.” These statements clearly set out the concrete policy changes the company is advocating. Taken together, the company offers comprehensive transparency across the policies it lobbies, the mechanisms it uses, and the outcomes it pursues. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Boston Scientific discloses a basic framework intended to keep its policy engagement in line with its climate strategy, stating that "our overall climate strategy … is considered at the onset of all activities that influence policy" and that such activities are "supported by our ESG Executive Steering Committee" as well as a "cross-functional CSR Council" and EHS policies, indicating an internal body with responsibility for overseeing external engagement. The company also describes a concrete review step for at least one piece of direct lobbying, noting that it has "evaluated" its support for the Irish Government Climate Action Plan and confirmed it is "aligned" with the Paris Agreement, which shows some mechanism for checking direct advocacy against climate goals. However, the disclosure reveals little active management of indirect lobbying: for both the National Association of Manufacturers and the U.S. Chamber of Commerce the company records its stance as "Unknown," admits "No, we did not attempt to influence their position," and adds "No, we have not evaluated" alignment with global climate treaties, suggesting that trade-association activity is neither systematically monitored nor corrected. The process description is high-level and does not specify the frequency, criteria, or outcomes of reviews, and no public climate-lobbying audit or board-level sign-off is mentioned. This indicates a moderate level of lobbying governance, with some oversight and direct-alignment checks, but limited transparency and no clear mechanism to manage or align indirect lobbying positions. 2