ArcelorMittal SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	ArcelorMittal discloses an integrated governance framework that explicitly links its climate objectives with the oversight, monitoring and correction of both direct and trade-association lobbying activities. The company states that it is committed to conducting all its direct and indirect policy lobbying and advocacy work in line with the Paris Agreement and has established clear escalation measures including direct communication requesting further alignmentringfenc[ing] our financial contribution and ceasing our membership, demonstrating a mechanism for enforcing alignment. Oversight is anchored at board level where The Sustainability Committee of the Board meets quarterly to review Sustainability matters of the company. This includes high level policy asks, while climate-specific policy engagement is further scrutinised by the executive-level Climate Change Committee, the ARCGS Committee and the Group Climate Council [whose] members include VP government affairs. The company also provides public, systematic reviews of lobbying alignment: In January 2022, ArcelorMittal published its second Climate Advocacy Alignment report which maps the policy positions of the 61 associations, following earlier periodic assessment of industry associations in 2020 and 2022. These published reports cover indirect lobbying and drive follow-up action, as the company notes that it is continu[ing] to engage with industry associations that were found not to be fully aligned until the publication of our next report. Direct lobbying is governed through internal principles and sign-off processes led by our Government Affairs teams, and every two years the company performs an assessment of advocacy engagements with trade associations and other organizations to assess their alignment. This suite of public reporting, recurring assessments, board-level oversight and defined corrective measures indicates a comprehensive governance system; the only area the company does not elaborate on is how individual direct-lobbying campaigns are evaluated in real time, but the existing disclosures nonetheless show strong, transparent and proactive control of climate-related lobbying. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

ArcelorMittal discloses an integrated governance framework that explicitly links its climate objectives with the oversight, monitoring and correction of both direct and trade-association lobbying activities. The company states that it is committed to conducting all its direct and indirect policy lobbying and advocacy work in line with the Paris Agreement and has established clear escalation measures including direct communication requesting further alignmentringfenc[ing] our financial contribution and ceasing our membership, demonstrating a mechanism for enforcing alignment. Oversight is anchored at board level where The Sustainability Committee of the Board meets quarterly to review Sustainability matters of the company. This includes high level policy asks, while climate-specific policy engagement is further scrutinised by the executive-level Climate Change Committee, the ARCGS Committee and the Group Climate Council [whose] members include VP government affairs. The company also provides public, systematic reviews of lobbying alignment: In January 2022, ArcelorMittal published its second Climate Advocacy Alignment report which maps the policy positions of the 61 associations, following earlier periodic assessment of industry associations in 2020 and 2022. These published reports cover indirect lobbying and drive follow-up action, as the company notes that it is continu[ing] to engage with industry associations that were found not to be fully aligned until the publication of our next report. Direct lobbying is governed through internal principles and sign-off processes led by our Government Affairs teams, and every two years the company performs an assessment of advocacy engagements with trade associations and other organizations to assess their alignment. This suite of public reporting, recurring assessments, board-level oversight and defined corrective measures indicates a comprehensive governance system; the only area the company does not elaborate on is how individual direct-lobbying campaigns are evaluated in real time, but the existing disclosures nonetheless show strong, transparent and proactive control of climate-related lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	ArcelorMittal provides an extensive and detailed picture of its climate-policy lobbying. The company names a wide range of concrete measures it engages on, including the EU Emissions Trading System, the Carbon Border Adjustment Mechanism, the Renewable Energy Directive, EU state-aid rules for energy and environment, the EU ETS Innovation Fund and Important Projects of Common European Interest, among others, showing full transparency about the specific policies, laws and regulatory initiatives it seeks to influence. It is equally explicit about how it lobbies: the group says it acts “usually in coordination with the applicable business associations in country e.g. Eurofer” and “when appropriate, we engage directly with national/regional governments,” while also publishing its own manifesto addressed to “member states and MEPs,” taking part in European Commission expert groups and holding direct discussions with the Polish Government, the European Commission and other named public officials. Finally, ArcelorMittal sets out the precise outcomes it wants, such as strengthening CBAM so that “steel-intensive finished products” and exports are covered, retaining free ETS allowances during a transition phase, securing “predictable access to abundant and affordable clean energy,” obtaining “public funding to cover 50 % of the cost” of its decarbonisation projects, and establishing storage targets for CCS. These clear positions, with explanations of why they are sought, demonstrate a high level of transparency across policies lobbied, mechanisms used and outcomes pursued.	A