Commercial Metals Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Commercial Metals Company offers only limited transparency around its climate-related lobbying. It notes that it works through industry bodies such as the Steel Manufacturers Association, EUROFER, the Concrete Reinforcing Steel Institute and the Global Steel Climate Council and that its Government Affairs team and an employee political action committee support these efforts, but it does not identify the specific legislators, agencies or jurisdictions it approaches. The company refers in broad terms to policy areas like fair commerce and trade, the circular economy, decarbonisation standards for steel and alignment with the Paris Agreement, yet it does not name any concrete bills, regulations or rulemakings it has tried to influence. Likewise, the objectives it says it pursues—maintaining competitiveness for lower-carbon U.S. steel and ensuring “level playing-field” trade rules—remain high-level themes, with no indication of the precise amendments, targets or timelines it is advocating. As a result, stakeholders are given only a general picture of the company’s lobbying activities rather than a detailed account of what policies it engages on, how it engages, and the specific outcomes it seeks.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Commercial Metals Co discloses limited information regarding its lobbying governance processes. The company mentions that its Board oversees sustainability issues, including receiving updates from the vice president of strategy, government affairs, and sustainability, who also directs sustainability strategy and oversees government relations and trade work. Additionally, the Sustainability Leadership Council (SLC) monitors risks and opportunities related to climate change and meets quarterly to review ESG performance. However, there is no explicit mention of a governance process for lobbying alignment, nor any detailed mechanisms for monitoring or managing lobbying activities, particularly in relation to climate goals. The evidence does not describe how lobbying activities are aligned with climate-related policies or whether direct and indirect lobbying are actively managed. Furthermore, while the vice president oversees government relations, there is no indication of specific processes or criteria for ensuring alignment of lobbying efforts with the company’s sustainability objectives.	1