This scorecard provides a detailed breakdown of InfluenceMap's assessment of Bayer's disclosures on climate policy engagement. This does not include an assessment of the company's real-world climate policy engagement, which can be found on InfluenceMap's online profile of Bayer, accessible via the buttons on the right hand side of the page.
The disclosure assessments are directly integrated into the CA100+ Net Zero Company Benchmark as part of InfluenceMap's Climate Policy Engagement Alignment’ assessment, under two distinct indicators:
In 2023, InfluenceMap’s methodology to assess corporate disclosures on climate policy engagement was formally updated in line with the Global Standard on Responsible Climate Lobbying and stakeholder input. The detailed methodology - as well as additional resources including best practice guidance and Bayer's company profile - is accessible via the buttons on the right hand side of the page.
A summary of Bayer's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
| Indicator | Score |
|---|---|
| Accuracy of Climate Policy Engagement Disclosure | Partial, meets some criteria |
| Sub-Indicator | Score |
|---|---|
| Accuracy of Direct Climate Policy Engagement Disclosure | Yes, meets criteria |
| Accuracy of Indirect Climate Policy Engagement Disclosure | Partial, meets some criteria |
A summary of Bayer's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
The Review Score (0-100) assesses corporate performance against seven indicators, using the same traffic-light framework. A ‘Green’ scores 2 points, a ‘Yellow’ scores 1 point, and a ‘Red’ scores 0 points. This total is converted into a percentage from 0 to 100, calculated using the total number of points available (14). As such, only certain scores within the 0 to 100 range are possible under this methodology. A Review Score of 100 would indicate that a company has met all of the assessment criteria related to the review process.
| Date of Review | Score |
|---|---|
| November 2022 | 6/14 (43%) |
| October 2023 | 6/14 (43%) |
| April 2025 | 7/14 (50%) |
This is an assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
InfluenceMap utilizes its proprietary database to assess how corporate disclosures on climate policy positions and engagement activities compare to InfluenceMap's independent assessment of the companies' and industry associations' real-world climate policy engagement. In short, it assesses the extent to which the company has disclosed on all climate policy engagement identified by InfluenceMap's database.
The tables below provide: (1) a breakdown of Bayer's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company published an accurate account of its corporate climate policy positions and engagement activities (as compared to InfluenceMap’s database)?
Bayer has published a broadly complete account of its positions and engagement activities on specific climate-related policies, but excludes 1 material evidence of direct climate policy engagement identified by InfluenceMap's database.
Bayer's 2024 Climate Advocacy Review includes reference to the company’s direct advocacy on specific climate-related policies from 2024, including the EU Certification of Carbon Removals Framework, EU Renewable Energy Directive III, and EU 2040 Target.
However, Bayer has excluded its engagement on crop-based biofuels in the US, despite engaging on the policy in July 2024 comment to policymakers.
Enel has published a complete and accurate account of its positions and engagement activities on specific climate-related policies, and this is aligned with InfluenceMap's assessment of the company using its LobbyMap database. Enel included its climate advocacy activities, positions, and links to the company’s government consultation responses to specific climate-related policies from 2022-2024 in its 2023 Climate Policy Advocacy report, published April 2024. It also covered a range of regions in its disclosure, including Global, Europe, North & South America, Africa, and the Asia Pacific.
BP partially met the assessment criteria under this indicator, as it excluded material evidence of climate policy engagement. However, BP’s ‘Advocacy Activities’ webpage provides a clear and detailed disclosure of the company’s climate policy engagement, with filters for jurisdiction; date; and topic, including links to relevant consultation responses. It also contains sorting options for most recent, and most relevant.
Has the company published an accurate account of the climate policy positions and engagement activities of the industry associations of which it is a member (as compared to InfluenceMap’s database)?
Bayer has published a partial account of its industry associations' positions and engagement activities on specific climate-related policies.
The company linked the LobbyMap profiles of 8 industry associations actively engaging on climate policy, such as Asociación Nacional de Empresarios de Colombia (ANDI) and Cefic. It provided accounts of the detailed climate policy engagement activities of its industry associations with specific policies, across 13 key jurisdictions.
Overall, Bayer only excluded material evidence of indirect climate policy engagement identified by InfluenceMap's database for 2 industry associations. For example, Bayer did not disclose multiple pieces of material evidence by the Confederação Nacional da Indústria (CNI) such as a November 2024 statement from that advocating for measures that risk fossil fuel lock-in, a June 2024 press release that appeared supportive of the Brazil Forest Code, and a July 2024 comment that supported the scale up of renewable energy.
It also did not disclose comments to policymakers submitted by the Confederation of Indian Industry (CII) in February 2024 that appeared to advocate for the use of biomass over fossil fuels as an auxiliary fuel as an energy input for waste incinerators.
Unilever has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. In its March 2024 industry association review, the company attached LobbyMap profile links to each association’s assessment. Iberdrola published a largely complete and accurate of its industry associations' positions and engagement activities on specific climate-related policies.
Iberdrola and its North American subsidiary Avangrid both disclosed the climate policy engagement activities of their industry associations in their respective industry association climate lobbying reviews.
This is an assessment of the quality and robustness of a company's processes to identify, report on, and address specific cases of misalignment between its climate policy engagement activities (direct and indirect) and delivering the 1.5°C goal of the Paris Agreement.
The Review Score is split into seven indicators, which fall within one of three categories:
Review Process: Does the company have clear and robust governance processes to regularly assess alignment against the 1.5°C goal of the Paris Agreement, and address potential cases of misalignment?
Review Assessment (Direct - Company): Has the company identified and addressed specific cases of misalignment between its direct - i.e. corporate - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
Review Assessment (Indirect – Industry Associations): Has the company identified and addressed specific cases of misalignment between its indirect – i.e. via industry associations - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
The table below provides an overview of Bayer's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.
| Review Process | Review Assessment (Direct) | Review Assessment (Indirect) |
|---|---|---|
| Monitor & Review | Identify & Assess | Identify & Assess |
| Alignment Assessment Method | Act | Act |
| Framework for Misalignment |
The tables below provide: (1) a breakdown of Bayer's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company established an annual monitoring and review process to ensure that all of its direct and/or indirect climate policy engagement activities across all geographies are consistent with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels?
Bayer has published reviews annually since 2021. Additionally, it has committed to publish an update to its 2024 report for 2025, and to publish a more comprehensive assessment for 2026 also.
Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2024, with detailed updates on misaligned industry associations each year. The company has committed to continue reviewing its memberships on an annual basis. Alternatively, Shell publishes a detailed review of its climate policy engagement every two years, with a detailed update in the interim year.
Has the company disclosed a clear and detailed framework for assessing alignment, including: (1) the criteria it uses to assess whether its climate policy engagement activities (direct or indirect) align with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels; and (2) a clear and detailed explanation behind each evaluation?
In its April 2025 review, Bayer disclosed a detailed methodology for assessing the alignment of its industry associations. The company uses eight sub-criteria to assess alignment with both Bayer’s positions and the Paris Agreement. The eight criteria are as follows: support the transition to net-zero; policies to enable net zero; lower reduce GHG emissions in agriculture by 30%; promote technologies and innovation to improve climate performance; source 100% of electricity from renewables by 2029; market-based approaches to carbon pricing and trading; acknowledge climate-related trade measures within a rules-based trade system; and carbon offsetting and natural climate solutions to deliver net zero. The company explains what constitutes findings of ‘alignment’, ‘partial misalignment,’ ‘misalignment’, ‘neutral’, or ‘no position’ against these sub-criteria, which is determined by the extent to which the association is aligned with Bayer’s own positions related to these policy areas. However, as noted in the assessment indicators below, it is not clear that Bayer’s own positions are always consistent with science-aligned policy pathways for delivering the 1.5°C goal of the Paris Agreement.
Each association receives an overall ‘Paris Agreement alignment’ assessment, which factors in both top-line support for the Paris Agreement, and whether the association’s advocacy activities align with Bayer’s positions. Bayer’s evaluation of alignment under each sub-criteria is accompanied by a short description which summarizes the rationale behind its finding. These evaluations are made with reference to the policy positions linked in the source section for each association.
While Bayer states that its positions are informed by the latest climate science, including that of the Intergovernmental Panel on Climate Change (IPCC), it is not clear from the review document whether the company has assessed its industry associations’ detailed engagement activities against science-aligned policy pathways for delivering the 1.5°C goal of the Paris Agreement. The company’s criteria for assessing alignment appears to be based on its own operational decarbonization targets, such as sourcing 100% of electricity from renewable energy by 2029, rather than against science-aligned policy pathways.
In addition, Bayer’s assessments appear to be limited top-line positions in several instances – including in its assessments of BusinessEurope, VCI, and the BDI – referring to positions on COP, the Antwerp Declaration, or the EU Green Deal, but not covering evidence of detailed advocacy on other climate-related policies that will be necessary to deliver the goals set out in these broad frameworks. In other instances, the company links to detailed misaligned policy positions from the LobbyMap database – such as an April 2023 article from BDI in which it was unsupportive of renewable energy legislation – but finds the association to be aligned on the relevant policy area and overall.
However, in its assessment of other associations – such as the US Chamber and the National Mining Association – it has referred to detailed policy positions, such as positioning on a long-term role for fossil fuels and GHG emissions regulations and assessed these against science-aligned policy pathways.
Unilever assessed its industry associations’ climate policy engagement against both its own climate policy positions, and against science-based policy, determined by “what the Intergovernmental Panel on Climate Change (IPCC) has said is needed to keep global warming below 1.5°C”. Unilever states that this assessment does not mean associations should be expected to support every proposed climate law, but that when an association opposes a specific climate policy, it is incumbent on the association to engage constructively with policymakers to help find alternative, viable policy options that would be (at least) equally effective at reducing emissions.
The company also clearly disclosed the criteria for findings of alignment and misalignment with both its own policy positions and science-based policy, and measured the engagement intensity of each association. It also provided clear and detailed explanations behind each evaluation including their detailed policy positions and links to each industry association’s LobbyMap profile.
Has the company established a clear framework to address misalignments between its climate policy engagement activities (direct or indirect) and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, including the escalation strategies it will use and when it will use these escalation strategies?
In its April 2025 review, Bayer stated that it continues to utilize the framework outlined in its 2021 review for addressing misalignments. This framework is carried out through two phases and includes escalation strategies and timelines for misaligned associations which do not amend misaligned practices.
Under the “Engagement Process” phase, Bayer will examine the circumstances of misalignment, seek understanding, proactively engage, and seek a more active role in the association. Under the “Remediation Process” phase, steps include undertaking a formal review with a clear timeline, making a public statement on the misalignment, pursuing further measures to exert influence on a policy change, preparing an ultimatum, and leaving the industry association with an annual review for re-joining.
In 2021, Bayer stated that it will set a clear timeline for the review and a deadline for action. In 2025, it reiterated that the company expects this process to prove sufficient within one year of publication in most instances of misalignment. Additionally, in 2025, Bayer stated that, while it is willing to leave a misaligned association, if necessary, it believes it can have a greater positive impact by exerting influence from the inside.
Iberdrola has disclosed a clear and detailed framework to address potential misalignments, including escalation strategies and deadlines for industry associations that do not amend misaligned practices. Iberdrola's escalation strategy includes engagement with the industry association, sending a "notification of dissatisfaction", and formal notification that a termination of membership is being assessed. If the association does not provide a clear and credible action plan to address the misalignment within 12 months, Iberdrola will implement one or more of the following actions: make a clear public statement regarding the misalignment, request the industry association refrains from engaging on misaligned issues, and/or suspension or discontinuation of membership.
Has the company identified and reported on the existence of all misalignments between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database (including all of its subsidiaries, business areas, and operational jurisdictions)?
Bayer has assessed the alignment of its direct climate policy engagement activities against its own corporate transition strategy, which it states is aligned with the 1.5ºC goal of the Paris Agreement. It also states that its positions are informed by the latest climate science, including that of the IPCC.
However, the company has not identified two cases of potential misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. For example, in July 2024 comments submitted to the U.S. Department of Agriculture, the company advocated for crop-based biofuels without acknowledging the need to manage sustainability risks or acknowledging the limitations to GHG emissions savings. This follows on from a November 2023 joint letter to the U.S. Treasury Secretary which was not covered in the company’s last review, in which Bayer advocated for less stringent criteria than ICAO's CORSIA methodology on the inclusion of agricultural management in lifecycle analysis of SAFs.
At the time of this assessment, Bayer has a LobbyMap Organization Score of 66%, indicating that the company’s direct climate policy engagement is partially aligned with science-aligned pathways for delivering the 1.5ºC goal of the Paris Agreement. Please see Bayer’s profile in the LobbyMap database for additional details on the company's real-world climate policy engagement activities.
Danone assessed 12 of its own climate policy positions and engagement activities across Europe, the US, and globally. It found all 12 to be aligned. According to InfluenceMap’s database, Danone does not appear to have any material evidence of negative climate policy engagement during the reporting period. As a result, Danone has assessed its climate policy engagement activities in line with InfluenceMap’s findings. It is the only company to have ‘broadly met’ the criteria for this indicator.
Sasol published a detailed review of its direct climate policy engagement in August 2023. Sasol assessed the alignment of five of its own climate policy positions, including four in South Africa (Climate Change Bill; Carbon Tax; PCC Just Transition Framework; Upstream Oil and Gas Tax Regime Discussion Document) and one in the EU (European Union Delegated Acts). However, Sasol did not identify any cases of misalignment with its own climate policy engagement. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. The company has not updated its review in 2024.
As a result, no company has shown evidence of identifying cases of misalignment of its direct climate policy engagement and delivering on the 1.5°C goal of the Paris Agreement.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
Bayer did not identify any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement from 2024. As such, the company has shown no evidence of action to address cases of misalignment in this area.
Danone and Unilever are the only companies to have ‘broadly met’ the criteria for this indicator by default. Both companies do not appear to have any material evidence of negative climate policy engagement according to InfluenceMap’s database, and therefore have no cases of misalignment to act upon.
As a result, no company has actively shown evidence of acting to address cases of misalignment between its own direct climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.
Has the company identified and reported on the existence of all misalignments between the climate policy engagement activities of its actively engaged industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
Bayer assessed 63 associations in its 2025 review, covering all actively engaged associations which it holds memberships to on the LobbyMap database.
Bayer identified overall Paris Agreement misalignment with two associations, one of which is covered by the LobbyMap database (National Mining Association (NMA)), and eight instances of overall partial misalignment with the Paris Agreement, one of which is covered by the LobbyMap database – US Chamber of Commerce. Additionally, it identified 29 cases of partial misalignment with 21 associations and 9 cases of misalignment with 3 associations across its specific sub-criteria.
InfluenceMap analysis indicates that the company has at least 4 memberships to industry associations with active climate policy engagement misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database), including BusinessEurope, NMA, the German Chemical Industry Association (VCI), and the US Chamber of Commerce. It also holds membership to at least 11 industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).
Of the four associations assessed as misaligned by InfluenceMap, Bayer identified misalignment with one (NMA), while identifying partial misalignment with another (US Chamber of Commerce). It also identified partial misalignment on one sub-criteria (policies to enable net zero) with the VCI.
The company did not identify any cases of overall partial misalignment identified by InfluenceMap (Appendix A). However, it did identify cases of partial misalignment on specific sub-criteria with National Business Association of Colombia (ANDI) the Federation of German Industries (BDI).
There appeared to be some inconsistency in the application of the company’s alignment assessment method, as it identified misalignments with some groups by assessing detailed policy positions against science-aligned pathways, while for others, it assessed top-line positions and/or did not identify misalignments demonstrated in detailed policy positions referenced in the review.
As a result, the company has not identified key cases of misalignment and partial misalignment between its industry associations and delivering the 1.5°C goal of the Paris Agreement in line with InfluenceMap’s database.
Unilever assessed 27 industry associations in its review and identified all cases of misalignment and partial misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database. Unilever has membership to 1 misaligned industry association (Tennessee Chamber of Commerce & Industry), and 10 partially aligned associations.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between the climate policy engagement activities of its industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
Bayer has shown some evidence of action to address misalignments. The company includes a case study of ‘engagement in action’ – stating that it has supported three industry associations globally (Confederation of Indian Industry (CII), American Chamber of Commerce, CropLife America) to advocate for policies which support its key priorities. For example, Bayer initiated a task force at the Confederation of Indian Industry (CII) to help it balance the “diverse viewpoints of its wide range of members” on issues relating to sustainable agriculture. However, it is unclear if the remit of this engagement included climate policy. Likewise, it is unclear how Bayer engaged the American Chamber of Commerce and CropLife America on reforming their climate policy advocacy. While Bayer shares some information regarding policies and initiatives these groups have supported, Bayer’s role in relation to these is not stated.
In the appendix, for each association assessed, it has included a section titled ‘Actions Taken and Results’, detailing instances in which Bayer has engaged with an association to address misalignments. For example, Bayer states that it found Cefic to be partially misaligned on the area of 100% renewable energy by 2030 in its last review, thus it has engaged with Cefic to clarify its positioning on this and has since found alignment with the group. It is noted that, while InfluenceMap analysis suggests while Cefic has not engaged negatively on renewable energy specific policy during Bayer’s assessment period, it remains partially aligned on climate policy engagement overall (Appendix A).
Also included for each association is a section titled ‘Next Steps’, wherein, for associations with findings of partial and full misalignment (e.g. U.S. Chamber), Bayer states that it will engage to “clarify and seek redress” on the issues of misalignment it has identified, although with limited further details provided. Despite finding misalignment with the NMA, Bayer states that it plays a minimal role within the NMA and therefore will not take action to address climate policy engagement misalignments.
Further, as Bayer has not identified multiple instances of its industry associations’ partial or full misalignment with delivering the 1.5°C goal of the Paris Agreement, as identified by InfluenceMap’s database, it has not shown evidence of action to address key misalignments.
Unilever is the only company to have met investor expectations in this area, showing evidence of action to address all cases of misalignment between its industry associations and delivering the 1.5⁰C goal of the Paris Agreement, as identified by InfluenceMap’s database. In its review, the company included a section for each association titled “Actions (to be) taken” in which it outlined the actions taken or to be taken with the industry association as per its assessment. For example, Unilever stated that it would write to the Tennessee Chamber of Commerce & Industry stating that their positions do not reflect those of Unilever. It also disclosed it would encourage the European Roundtable for Industry to continue to engage constructively on the EU Green Deal and explore how it can revise its position on the EU Emissions Trading System.
Additionally, Unilever stated that for the 12 associations that were deemed “passively aligned” (minimal to non-existent policy engagement), the company will aim to push the associations to become more actively engaged in promoting outcomes and policies that aid in decarbonization.
Yes, meets criteria
Partial, meets some criteria
No, does not meet criteria
The table below provides a ranking of Bayer's industry associations currently covered by InfluenceMap’s database by Performance Band, i.e. a full measure of a company’s climate policy engagement, accounting for both its own engagement and that of its industry associations. Detailed profiles for all industry associations can be explored via the links in the table.
Industry associations are categorized by InfluenceMap as having climate policy engagement that is aligned, partially misaligned or misaligned with delivering the 1.5°C goal of the Paris Agreement by Performance Band:
The ranking table below is updated automatically on a continual basis as: (1) new evidence is collected for the industry associations; (2) new industry associations are added to the company profile; (3) industry associations are removed from the company profile, e.g. if the company leaves the association.
As such, the industry associations and/or scores in the ranking table below may differ from the findings in Identify & Assess (Indirect) above, which was written on the date of assessment. See the top of this page for the date of assessment.
