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ATI’s disclosures focus extensively on climate-related oversight by its Board and management—its Board “actively oversees matters of key importance to the overall conduct of our business, including ... the identification and mitigation of known and emergent enterprise risks and opportunities, including those pertaining to environmental, workforce and community, and safety and sustainability” and its Audit and Risk Committee assists in oversight of “risks to the Company and its business, operations and results, associated with climate change and other environmental compliance and sustainability matters,” while the Executive Council is “responsible ... for overseeing the identification, evaluation, and management of enterprise risk and for developing and implementing ... strategy, including with regard to climate change.” However, the company does not disclose any mechanisms for governing its lobbying activities—there is no mention of policies, structures, or processes for aligning direct or indirect lobbying with its climate or other policy objectives, nor any specific individual or formal body tasked with oversight of lobbying alignment, and we found no evidence of a lobbying governance framework in the disclosures.
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