CNH Industrial NV

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	CNH Industrial provides a highly detailed picture of its climate-policy lobbying. It names a wide range of specific measures it has engaged on, including the “Revision of CO2 Regulation of Light Duty Vehicles,” the “Revision of CO2 Regulation of Heavy-Duty Vehicles,” the EU “Eurovignette Directive,” Regulation (EU) 510/2011, Article 13 of Regulation 2019/1242, the U.S. “Consumer and Fuel Retailer Choice Act,” “Year-Round Fuel Choice Act,” the “45W tax credit” in the Inflation Reduction Act, and the “Advancing IoT for Precision Agriculture Act,” among others, demonstrating full transparency about the policies addressed. The company also spells out how and with whom it lobbies, citing “continuous direct participation in meetings with the Directorate General CLIMA and Directorate General GROW (European Commission),” “active participation in dedicated ACEA working groups and meetings with the EU Commission,” collaboration through trade associations such as OICA, NGVA Europe and EUROMOT, and attendance at UNECE stakeholder sessions (e.g., WP15, WP29, GRSG 114). These descriptions identify both the mechanisms—meetings, technical workshops, working groups, association submissions—and the precise governmental or multilateral targets. Finally, CNH Industrial is explicit about what it wants to achieve. It seeks “to reward renewable fuels like biomethane in the CO2 regulation,” to secure eligibility of agricultural and construction equipment for the 45W electric-vehicle tax credit, to drive “wider ethanol adoption,” to “properly reward zero-emission trucks like Hydrogen Fuel Cell Vehicles and Battery Electric trucks through full or partial exemption from the road toll charging system,” and to ensure zero-emission light commercial vehicles are “not penalized for the additional weight” of alternative traction systems. It also backs visual-inspection rules for CNG cylinders and improved standards for CNG/LNG refuelling infrastructure. By clearly identifying the policies it works on, the channels and bodies it uses to advocate, and the concrete legislative and regulatory changes it seeks, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	CNH Industrial NV has established a governance framework for ensuring its policy engagement aligns with its climate commitments by relying on its Code of Conduct and related policies and procedures. As the company states, “CNHI uses the Code of Conduct, its policies, and related procedures to ensure a consistent Company-wide approach in line with its climate change strategy, and regulate CNHI’s relationships with various types of public and private organizations,” and this framework extends to both its direct advocacy through its Institutional Relations functions and its indirect engagement as a member of industry associations. Oversight of these activities is clearly assigned, with “the highest responsibility for CNHI’s Institutional Relations” resting with the Senior Leadership Team (SLT), while each geographic unit is responsible for “monitoring policy trends and engaging with public authorities, trade associations, international organizations, business sector, and NGOs in the institutional and regulatory decision-making processes.” CNH further demonstrates alignment of its indirect lobbying priorities by participating in bodies such as ACEA and Hydrogen Europe that “support the public debate and legislation to foster the clean energy transition and the future zero-emission mobility.” However, the company does not disclose any dedicated procedures or review processes—such as a climate-lobbying audit, explicit sign-off mechanisms, or criteria for reassessing associations—to systematically evaluate and manage the alignment of its lobbying positions.	3