Howmet Aerospace Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Howmet Aerospace provides a solid level of transparency around its climate-policy lobbying. It names a broad suite of specific measures it has worked on, including the US SEC’s proposed climate-disclosure rule, the EU Corporate Sustainability Reporting Directive, California’s Climate Corporate Data Accountability Act and Climate-Related Financial Risk Act, as well as technical regulations such as the US EPA’s Cleaner Trucks Initiative and the forthcoming “Energy Efficiency for Trucks (NOx and Heavy Duty Truck GHG Phase III emissions regulations).” The company also explains how it lobbies, noting that it "engaged with policy makers and trade associations," and that it "supported development of trade association comments and engaged with EPA," explicitly identifying the US Environmental Protection Agency and the California Air Resources Board as targets. On outcomes, Howmet sets out what it is trying to achieve: it wants the EPA and CARB NOx programmes harmonised, to “enable multiple technology and product paths to achieve compliance,” to secure “incentives for early compliance,” and more broadly to align its engagements with the Paris Agreement, including a 33.6 % absolute Scope 1 & 2 reduction by 2027 and strengthened Scope 3 accounting. Collectively, these disclosures give a clear picture of what policies the company lobbies on, the channels it uses, and the specific results it seeks, though the description of mechanisms could be more granular.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Howmet Aerospace has put in place a periodic review process in which “Global Government Affairs and Environmental Health and Safety teams review and coordinate periodically actions on climate change among other Environmental policy related issues,” and it affirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” which indicates a policy-level pledge to align its advocacy with climate targets. The company also explains that “in addition to our individual efforts to shape policy, we also engage with many industry groups where our interests are aligned. These include regional associations,” showing both direct policy engagement and participation in trade-body activities. However, the company does not disclose a specific individual or formal governance body responsible for overseeing climate lobbying, nor does it describe detailed mechanisms for monitoring or enforcing alignment of association or policy positions with its climate strategy. We found no evidence of systematic audits or criteria for disengaging from groups whose positions conflict with its climate objectives.	2