CF Industries Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	CF Industries discloses a moderate level of detail on its climate lobbying activities. The company names specific policy areas, including advocacy for a U.S. carbon pricing system and a border adjustment mechanism, and notes its work through coalitions such as the Climate Leadership Council and Hydrogen Council to advance these measures. In terms of lobbying mechanisms, CF Industries states that "CF Industries is also directly engaged with policymakers to educate and work with elected officials and policymakers on matters that are important to the Company," and it highlights its participation in industry coalitions, but it does not identify which elected officials or government bodies are being targeted nor describe whether engagements occur via meetings, letters, or formal consultations. Regarding outcomes sought, CF Industries supports policies that incentivize decarbonization and clean energy initiatives, such as carbon capture and sequestration, advocates for a U.S. carbon pricing system "to prevent carbon leakage," and aims to "advance policies that will accelerate decarbonization globally to meet the world’s ambitious climate targets." These represent clear objectives, though without quantitative targets or detailed legislative amendments. Together, these disclosures reflect a moderate degree of transparency around CF Industries’ climate policy lobbying.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	CF Industries prepares a semiannual Political Contributions Report listing CF Industries’ political contributions, which is “posted on our corporate website” and “presented to the environmental sustainability and community committee,” and each report “sets forth the United States trade associations and other similar nonprofit organizations to which the company annually pays dues of $20,000 or more and identify[s] the portion of such dues that is used for advocacy and/or political activities.” It also makes its “code of corporate conduct, containing our corporate policies related to political activities and contributions, lobbying and related matters” publicly available. These disclosures demonstrate transparency in reporting contributions and some oversight by a formal committee, but the company does not disclose any process to ensure alignment of its direct or indirect lobbying activities with its climate or broader policy objectives, nor does it identify a specific individual or formal body tasked with reviewing or managing its lobbying alignment.	1