ICF International Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	ICF International has disclosed several specific climate policies it has engaged with, including the U.S. AIM Act’s hydrofluorocarbon phase-down—“Congress, through the AIM Act, directed the Environmental Protection Agency (EPA) to address the use of highly potent greenhouse gases… and lower their production and consumption in the U.S. by 85% over the next 15 years”—multiple amendments to the National Environmental Policy Act, and support for aligning the United States’ 2030 Nationally Determined Contribution under the Paris Agreement, as well as its engagement on the UNFCCC’s Enhanced Transparency Framework. However, it offers limited detail on its lobbying mechanisms: beyond describing broad technical assistance, the only specific action it cites is acting as a “signatory on a letter from over 400 businesses to President Biden urging alignment of the United States' NDC with the Paris Agreement,” without further mention of meetings, consultations, or targeted outreach. On outcomes, ICF clearly supports two defined objectives—the HFC phase-down and a 50% GHG reductions target by 2030—but does not consistently link its broader advisory work to additional legislative or regulatory goals. Taken together, its disclosures demonstrate a moderate level of transparency by clearly identifying key policies and select desired outcomes while remaining relatively opaque on the full breadth of its mechanisms and end goals.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	ICF International Inc. provides limited disclosure on governing its lobbying-related activities, primarily stating that "We do not engage in federal lobbying" and framing its government relations work as "consistent with corporate policies supporting independence" rather than detailing any oversight or approval structures. Although it affirms alignment between its public positions and climate strategy, noting that "Policymakers may read and be influenced by ICF’s work on climate change, however, we do not directly engage to influence policy because it could present a conflict of interest," the company does not disclose any formal review process, board or executive-level oversight, or monitoring mechanism for its engagement activities. It does indicate "Yes" in response to having "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," but this promise is not accompanied by details on how it is implemented or enforced. Overall, the disclosure on climate-related lobbying governance is minimal, with no named individual or committee overseeing those activities and no evidence of processes to manage direct or indirect advocacy.	1