Resolved clauseShareholders of Linde request that the Board of Directors prepare a report, updated annually, describing
whether and how Linde is aligning its lobbying activities, both direct and indirect (through trade associations, coalitions,
and other organizations), with its climate neutral by 2050 goal. Such disclosure, prepared at reasonable cost and
excluding proprietary information, could include the activities and positions analyzed, the criteria used to assess
alignment, and external stakeholders consulted, if any.
Whereas clauseThe United Nations Framework Convention on Climate Change asserts that greenhouse gas emissions must
decline by 43% from 2019 levels by 2030 and 65 percent by 2035 to avert the worst impacts of climate change, including
more frequent and severe droughts, heatwaves, and rainfall.1
Linde ("Company") acknowledges that promulgated regulations to reduce or mitigate the adverse effects of greenhouse
gas ("GHG) emissions would represent a significant cost for Linde and that losses could arise from the physical effects of
climate change.2 In response, the Company publicly committed to science-based 2035 GHG reduction targets and a 2050
climate neutrality ambition for its operational emissions.3 Linde has committed to conduct its engagement activities in line
with the goals of the Paris Agreement and recognized that strong policy support is required to achieve its climate goals.
However, the Company's disclosure of its lobbying activities is uneven, making it challenging for investors to evaluate
whether and how Linde's advocacy efforts are consistent with its commitment. For example, in its 2024 CDP
questionnaire, Linde provides some details of its indirect engagements on policy, however, the Company has not
disclosed annual dues paid to each organization that it is a member of, does not distinguish how actual trade association
lobbying activities align or misalign with Linde's climate neutrality ambition, and has not disclosed an assessment of its
membership in the American Fuel and Petroleum Manufacturers Association which has negatively engaged on climate.4
Inconsistencies in corporate lobbying between a company's climate commitments can contribute to delays in emissions
reductions which can harm shareholder value through increased physical risks to assets, abrupt policy changes, limited
access to capital and insurance, and escalating health costs.5
Linde has spent $8.8 million on federal lobbying since 2014.6 This does not include state lobbying, where Linde also
lobbies but disclosure is uneven or absent. The Company's disclosure is limited to a sentence referencing its two largest
public policy advocacy issues. In contrast, Honeywell, a key Linde competitor, has published a climate lobbying report7
with an assessment of Honeywell's lobbying activities
Supporting statementIn evaluating the degree of alignment between the Company's emissions goals and its
lobbying, the proponent recommends that the Company assess policy influence activities, such as comment submissions,
regarding climate provisions of legislation and regulation.
This request is generally consistent with the investor expectations described in the Global Standard on Responsible
Climate Lobbying8, which is a useful resource for implementation.