Primo Water Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Primo Water Corp’s disclosures focus on broad sustainability governance but make no mention of lobbying oversight or alignment processes. While the company explains that “Primo Water’s sustainability governance structure provides oversight of our sustainability priorities, implementation and accountability in execution” and that its “Board of Directors’ ESG and Nominating Committee… instructs our CEO and Executive Leadership Team,” with “Our Vice President of ESG… responsible for supporting and coordinating management’s sustainability process and activities, including embedding sustainability priorities into our strategic plan,” we found no evidence of any governance structure, policy, or oversight mechanism for either direct or indirect lobbying activities, nor any description of how lobbying alignment with climate or policy goals is monitored or who is responsible. The company does not disclose any process to evaluate its trade association memberships or to manage its public policy engagements, indicating the absence of a defined lobbying governance framework. View Sources	E

Overall Assessment

Analysis

Score

None

Primo Water Corp’s disclosures focus on broad sustainability governance but make no mention of lobbying oversight or alignment processes. While the company explains that “Primo Water’s sustainability governance structure provides oversight of our sustainability priorities, implementation and accountability in execution” and that its “Board of Directors’ ESG and Nominating Committee… instructs our CEO and Executive Leadership Team,” with “Our Vice President of ESG… responsible for supporting and coordinating management’s sustainability process and activities, including embedding sustainability priorities into our strategic plan,” we found no evidence of any governance structure, policy, or oversight mechanism for either direct or indirect lobbying activities, nor any description of how lobbying alignment with climate or policy goals is monitored or who is responsible. The company does not disclose any process to evaluate its trade association memberships or to manage its public policy engagements, indicating the absence of a defined lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Primo Water offers only limited transparency on climate-related lobbying. The company describes one instance of advocacy – meetings with members of the U.S. Congress during the International Bottled Water Association’s “Hill Day” to press for the inclusion of a water icon in the MyPlate dietary guidelines – and explains that the goal of this effort is to secure that specific policy change. While this disclosure names the lobbying mechanism (direct meetings) and the policymaking target (federal legislators) and sets out the desired outcome, it does not refer to any climate-related legislation, regulations or broader energy-transition measures. As a result, the information provided covers just a single, non-climate policy engagement and leaves other potential climate policy activities, mechanisms and positions unaddressed.	D