SKF AB

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	SKF AB provides a strong level of transparency on its climate-related lobbying. It names specific measures it has engaged on, including the EU’s “Carbon Border Adjustment Mechanism” and a “UK Government support scheme for renewable tidal energy,” and states that it has argued for “regulations that create incentives that promote circular use,” giving readers a clear sense of the policy areas it seeks to influence. The company also describes multiple, well-defined lobbying channels and the decision-makers it approaches: it held “direct discussions between EU staff developing this legislation and SKF’s International Trade department in Brussels,” attended “pre-meetings with ICC and the chief negotiator for the Swedish delegation” at COP 26, met “UK ministers” through a trade organisation to press for renewable-energy funding, and took part in SteelZero “closed sessions with business and government representatives” in South Korea and India, among others. Finally, SKF is explicit about the outcomes it wants, such as having “the cost of CO2e … internalized,” creating “a global standard and definition on what low-emission and net-zero steel is,” ensuring public-sector purchasing of low-carbon steel, and securing “financial support to renewable energy,” all of which it says are “aligned with the Paris Agreement” and the 1.5 °C goal. Together, these disclosures demonstrate clear positions, mechanisms and objectives for the company’s climate-policy advocacy.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	SKF AB has adopted a structured approach to governing its climate-related lobbying, chiefly through indirect channels, but does not disclose governance processes for direct advocacy. It has “procedures and guidance in place, following the principles of the Global Standard on Responsible Corporate Climate Lobbying” to ensure that “organizations in which we are members are in line with the principles set out in the SKF Code of Conduct and the Paris Climate Agreement 1,5 degree target.” Group Sustainability, “through the Director of Sustainability, is maintaining a list of all organizations to which the SKF Group Companies are a member of,” and this list “is reviewed and updated annually together with the local business areas,” with clear escalation measures stipulating that “if an organization does not comply with these principles the issue shall be escalated and SKF shall endeavor to change the organization or exit.” The policy also clarifies that “only the CEO may comment on political issues on behalf of the company,” delineating responsibility for direct lobbying. However, the company does not disclose any formal review or monitoring procedure for direct engagement with policymakers or a board-level oversight mechanism specific to its lobbying activities, nor does it cite any third-party assessments of its climate-lobbying alignment.	2