Alcoa Corp

## 1. GOVERNANCE

The highest level of direct responsibility for Climate Change Strategy is with the Safety, Sustainability and Public Issues Committee of the Alcoa Board of Directors. Decisions made at Executive Team level, and endorsed by the Board of Directors, are cascaded to all operations. [...] **Risk Management**: Climate change risks and opportunities are assessed at least annually as part of Alcoa's overall risk management process. Alcoa's risk management program is assessed at the company level. Single point accountability resides with the role of the Chief Financial Officer, but this is a joint effort among the entire management team of Alcoa. The results of the assessment are presented to the Executive Team and the Board of Directors and used in the annual strategic planning process. In 2019, Alcoa performed a first analysis following the recommendations of the Task Force on Climate Related Financial Disclosures (TCFD). This work will continue to be advanced and will be incorporated into the general risk management process.

Political Contributions Our Political Contributions Policy prohibits the use of Company funds, property, services or other items of value for political purposes. Rare exceptions may be made, such as favoring or opposing a ballot or referendum vote that can impact our Company. Alcoa Corporation did not make any direct donations to the election campaigns of politicians in 2022. As permitted by U.S. and state law, qualified Alcoa employees voluntarily donated approximately US$11,500 to U.S. candidates for political office in 2022 through the Alcoa Corporation Employees' Political Action Committee.

Alcoa's management closely monitors and coordinates the Company's public policy advocacy efforts, including lobbying activities, and the Safety, Sustainability and Public Issues Committee of the Board periodically receives updates from management regarding global public policy positions and engagement, including stakeholder considerations regarding such issues. The Safety, Sustainability and Public Issues Committee, which is comprised solely of independent directors and includes directors with significant experience in government, legal, and regulatory affairs, oversees Alcoa's policies and practices relating to the Company's political activities, as described in its publicly available charter. The Board believes that the additional disclosure regarding oversight of lobbying-related expenditures requested by the proposal is unnecessary in light of the existing disclosures regarding governance in place surrounding these activities.

**Our Approach**

Public policy issues are critical to our business. Alcoa Corporation ("Alcoa" or the "Company") uses public policy engagement to advocate for positions that advance our strategic priorities, including directly and indirectly through our membership in industry associations and organizations.

Alcoa maintains policies and procedures governing our public policy and engagement process, including political contributions and lobbying activities, that are consistent with our Code of Conduct and Ethics and support continued compliance with applicable laws and regulations.

Our political engagement is subject to oversight by the Company's senior and executive management. Executive management provides periodic updates to the Safety, Sustainability and Public Issues Committee of the Alcoa Corporation Board of Directors, which has oversight responsibility of the Company's political activities and matters of public policy and corporate citizenship, pursuant to its Charter.

**Lobbying Activities**

**Direct Lobbying**

Alcoa engages with government and regulatory officials in the countries and regions in which we operate on key issues and emerging risks and opportunities. Depending on the jurisdiction, this engagement includes advocating on environmental, climate, energy, taxes, critical minerals, and trade issues. Our public policy advocacy efforts follow applicable laws in each jurisdiction, and we report on those efforts and their expenses as required by law. For example:

* In the United States, the Company discloses its U.S. federal, state and local lobbying activity and expenditures as required by law. Each quarter Alcoa files form LD-2 to report its federal lobbying expenses to the Office of the Clerk of the House of Representatives and the Secretary of the Senate.
* In Canada, Alcoa reports to the Office of the Commissioner of Lobbying.
* In Europe, Alcoa reports to the EU Transparency Register.

Alcoa maintains a procedure to identify and screen potential lobbyists. All potential third-party lobbyists are reviewed through the Company's rigorous anti-corruption intermediary process, and strict accounting and compliance procedures facilitate compliance with applicable registration and reporting obligations.

**Industry Associations**

Alcoa belongs to several industry associations around the world in support of our strategic priorities. These associations play an important role in the aluminum industry and provide the Company opportunities to engage in the legislative and regulatory process and influence matters that impact the industry.

We actively participate in various trade associations and industry-based organizations to understand and manage risks associated with changing government policies and legal landscapes. [...] We recognize that not all industry associations' views may be fully aligned with the Alcoa's views. As such, the Company periodically evaluates our industry association memberships and policy alignment.

Where significant differences in policy positions arise, we may provide greater clarity on our own positions and work to share our position in the association. If differences remain significant, Alcoa will assess the value of the Company's in the association.