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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Cummins Inc. provides a highly detailed picture of its climate-policy advocacy. It identifies a wide array of specific measures it has worked on, including the “Inflation Reduction Act,” the “Securing America’s Clean Fuels Infrastructure Act,” the “Build Back Better Act,” EPA’s “Phase 3 Heavy-Duty GHG rule,” CARB’s “Heavy-Duty Engine and Vehicle Omnibus Regulation,” Euro VII standards, and initiatives such as federal “Hydrogen Hubs,” battery-policy provisions and the EU’s “Carbon Border Adjustment Mechanism.” The company also spells out how it engages: executives have “testified in front of the House Select Committee on the Climate Crisis and the House Energy and Commerce Environment and Climate Change Subcommittee,” met “with Members of Congress and the Administration, including the President,” submitted feedback to the EPA’s Cleaner Trucks Initiative, hosted EU policymakers at its Belgian plant, and works indirectly through bodies like the U.S. Chamber of Commerce and the National Association of Manufacturers. Finally, Cummins is explicit about what it is trying to secure from these efforts, backing “tax credits for hydrogen production and clean trucks,” seeking “robust federal investment in clean energy technologies,” urging the EPA to issue “a tough, clear and enforceable Phase 3 final rule” and to “lower the NOx standard for heavy-duty on-highway engines,” while advocating economy-wide carbon pricing to align with its PLANET 2050 net-zero target. Together, these disclosures demonstrate a comprehensive level of transparency across the policies addressed, the channels used, and the concrete outcomes the company is pursuing.
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4
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| Overall Assessment |
Comment |
Score |
| Strong |
Cummins Inc discloses a structured governance architecture for ensuring that both its direct lobbying and its work through trade associations are aligned with its climate strategy. The Board-level Safety, Environment and Technology Committee is authorized to assist our Board [and] review public policy developments, strategies and positions taken by us with respect to safety, environmental and technological matters that significantly impact us, while the Government Relations team prepares a report on its progress and challenges for each regular board meetingtypically five times a year, indicating routine oversight. Operational responsibility rests with Catherine Van Way, Cummins Vice President of Government Relations, and specialist functions such as the Technical & Environmental Strategic Planning group which uses robust processes and guiding principles to direct Cummins environmental policy actions and ensure consistency and adherence to our environmental and climate strategies across all activities including public policy advocacy. The company states that these principles and our environmental mission apply to all direct and indirect activities including external relations, partnerships, and advocacy, and confirms a public commitment to conduct your engagement activities in line with the goals of the Paris Agreement. On indirect lobbying, Cummins evaluates the climate positions of its business partners for alignment with the goals and aspirations in the companys PLANET 2050 environmental sustainability strategy and has encouraged both [the U.S. Chamber of Commerce and NAM] to embrace climate science, also noting that it worked with the Business Roundtable to endors[e] carbon pricing, demonstrating active engagement to bring trade associations into line with its climate stance. While these disclosures show clear processes, named accountability and evidence of efforts to influence external bodies, the company does not disclose publishing a dedicated, comprehensive climate-lobbying alignment audit or any formal criteria for withdrawing from misaligned associations.
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3
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