Xylem Inc/NY

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Xylem discloses a wide-ranging and detailed picture of its climate-related policy engagement. It names numerous specific measures it has lobbied for or helped shape, including U.S. legislation such as the “Tribal Access to Clean Water Act of 2021,” the “Water Infrastructure Modernization Act of 2021” (and the 2023 version, H.R. 3590), draft provisions requiring a “Digital Climate Solutions Report,” and the “U.S. and Canada Pump Energy Conservation Standards,” as well as EU files like the revision of the Urban Wastewater Treatment Directive and the review of Commission Regulation (EU) 547/2012 and related Ecodesign Lots 28 and 29. The company also outlines how it conducts this advocacy: it describes direct work “with Members of Congress,” the submission of “content and feedback on drafts of legislative documents,” participation in congressional panels during Infrastructure Week, and technical engagement through trade associations such as Europump, the Hydraulic Institute and the Water and Wastewater Equipment Manufacturers Association, all of which interact with clearly identified targets including the U.S. Congress, the Department of Energy, the Environmental Protection Agency and the European Commission. Finally, Xylem is explicit about the outcomes it seeks—securing grant funding for smart-water technologies, achieving energy neutrality and nitrous-oxide reductions in wastewater treatment plants, expanding access to clean water for Native communities, and adopting an “Extended Product Approach” to improve pump energy performance—demonstrating clear positions and measurable objectives for each policy engagement. Together these disclosures provide a comprehensive and transparent account of the company’s climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Xylem outlines a formal governance structure that links its climate strategy to public-policy engagement, noting that “Our ESG Committee is composed of representatives from multiple geographies, businesses and functions and is under the executive sponsorship of the SVP, General Counsel and Corporate Secretary…”. The company states that this committee is responsible for “Coordinating company responses to strategic public policy and regulatory issues” and operates under a mandate to “ensure that your engagement activities are consistent with your overall climate change strategy”. This indicates that a named body with senior-level oversight meets regularly to review policy engagement and align it with climate objectives, which shows a clear though limited process for governing lobbying activities. However, the disclosure does not describe how the company monitors or evaluates the alignment of specific direct lobbying actions or its memberships in trade associations, nor does it publish any dedicated lobbying-alignment assessment or detail consequences for misalignment. The evidence therefore points to moderate governance centred on an internal committee but provides no visibility into concrete monitoring mechanisms, trade-association reviews, or public reporting of lobbying alignment. 2