Keurig Dr Pepper Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong Keurig Dr Pepper discloses a solid list of the climate-related policy measures it seeks to influence, naming federal bills such as “The Recycling and Composting Accountability Act,” “The Recycling Infrastructure and Accessibility Act of 2023,” its support for enhanced recycling funding within the U.S. bipartisan Infrastructure Investment and Jobs Act, and state- and provincial-level Extended Producer Responsibility (EPR) programs in California, Colorado, New Jersey, New York, Oregon, Washington and Canada. This demonstrates a high degree of transparency about the specific legislative files on which it is active. The company also outlines the channels it uses—“direct engagement with public officials” and participation in “trade associations, coalitions and stakeholder convenings,” and notes that “Information pertaining to our direct engagement and associated expenditures are reported to the U.S. Congress in accordance with the Lobbying Disclosure Act of 1995.” However, it does not go on to identify which lawmakers, agencies or parliamentary committees it addresses, so the description of its mechanisms remains general rather than granular. KDP is clearer about the outcomes it seeks, advocating for “the creation and successful implementation of EPR programs” and for “enhanced recycling-related federal funding for collection and education,” and supporting passage of the two federal recycling bills in order to “improve the nation’s recycling infrastructure” and lower economic and environmental costs. By explicitly connecting each named policy to the result it wants to see, the company provides meaningful insight into its lobbying objectives even though the identities of its lobbying targets are not revealed. 3
Lobbying Governance
Overall Assessment Comment Score
Moderate Keurig Dr Pepper maintains a formal oversight framework for its public policy advocacy, with the “KDP Board of Directors has oversight responsibility over our public policy advocacy, including our lobbying, KDP Political Action Committee activities, and payments to trade associations and other tax-exempt organizations that may be used for political purposes” and the Vice President of Government Affairs “is responsible for managing KDP’s public policy engagement strategy and regularly reviews our legislative priorities and political contributions with KDP’s Executive Leadership Team.” The company’s Government Affairs team addresses both direct lobbying and “memberships in trade associations” and states that “Our Vice President of Government Affairs, Chief Corporate Affairs Officer, and General Counsel review KDP’s engagement and continued alignment with trade associations and their issue specific policies annually,” demonstrating a mechanism for monitoring indirect lobbying. While Keurig Dr Pepper affirms that it has a public commitment to conduct engagement activities in line with the goals of the Paris Agreement and has a climate policy combining “mitigation, adaptation and engagement,” we found no evidence of a designated climate-lobbying review process or specific criteria to assess the alignment of its direct or indirect lobbying activities with its climate goals, and the company does not disclose any climate-specific lobbying audit or third-party assessment. This indicates strong overall lobbying governance with named oversight and indirect-review procedures, but weak transparency on how those structures specifically govern climate-related lobbying alignment. 2