Ballard Power Systems Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Ballard Power Systems provides a high level of detail on its climate-policy lobbying. It identifies a wide range of specific measures it has engaged on, including the Innovative Clean Transit and Advanced Clean Truck regulations in California, the Zero-Emission Vehicle mandate in British Columbia, truck-emission rules in the EU, Canada’s Hydrogen Strategy, and elements of the EU “Fit-for-55” package such as hydrogen supply quotas under the Renewable Energy Directive, hydrogen refuelling-station targets in the Alternative Fuels Infrastructure Regulation and the planned extension of the EU Emissions Trading System. The company also outlines how it lobbies, citing “engagement with policy makers in Canada, US and Europe directly or through industry associations and NGO's” and stating that it “provide[s] policymakers with data and insights to support the growth of the fuel cell industry and a clean energy sector.” Although it does not drill down to the level of individual officials or describe each contact method, it nonetheless discloses both direct engagement and work through associations across multiple jurisdictions. Finally, Ballard is explicit about what it wants to achieve: it supports zero-emission vehicle mandates and tighter emission regulations, seeks alignment of European state-aid rules so that fuel-cell manufacturing receives the same support as electrolyzers, and presses for rapid implementation of the Fit-for-55 agenda to accelerate large-scale deployment of hydrogen technologies. Together these disclosures give stakeholders a clear view of the company’s climate-related lobbying objectives, mechanisms and policy focus.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Ballard Power Systems discloses that the Board-level “Sustainability and Governance Committee… is responsible for overseeing… ESG performance, including the policies and practices related to ESG,” and that it has been delegated responsibility for “overseeing ESG issues, policies, public policy matters, ESG performance and ESG disclosures.” This indicates that a formal body of independent directors is charged with supervising the company’s approach to public policy engagement. The company also states that it has “process(es)… to ensure that your external engagement activities are consistent with your climate commitments,” citing a “stakeholder engaged materiality assessment… used to ensure alignment with our stakeholders on our priority ESG areas and climate change strategy.” However, the disclosure does not describe any specific mechanism for monitoring or approving climate-related lobbying positions, gives no detail on how direct or trade-association lobbying is reviewed, and does not name any individual executive responsible for lobbying alignment beyond broad ESG reporting. We found no evidence of a dedicated climate-lobbying review, public alignment report, or actions taken to address misaligned trade associations. As such, while Board-level oversight of public policy matters suggests some governance, the processes governing lobbying alignment are only briefly referenced and remain largely undefined.	1