Ball Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Ball Corporation has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly named specific climate-related policies it has engaged with, such as lobbying for the "Break Free From Plastic Pollution Act," supporting clean energy standards at the Arizona Corporation Commission, and advocating for Extended Producer Responsibility (EPR) and Deposit Return Schemes (DRS). Additionally, Ball disclosed its involvement in lobbying the European Commission to include "a 90% recycling target and support for DRS in its proposal for packaging waste regulations" and its participation in COP29, where it signed an open letter urging governments to adopt measures like effective carbon pricing and mandatory quotas for low-carbon materials usage. Ball has also provided detailed information about its lobbying mechanisms and target entities, including direct engagement with policymakers through letters and meetings, such as submitting a business letter to the Arizona Corporation Commission and meeting with the Arizona Chair Commissioner. It disclosed lobbying efforts with U.S. House and Senate members for specific legislation, participation in coalitions like the "Cambridge Institute for Sustainability Leadership's Corporate Leaders Group," and signing letters to legislators supporting clean energy generation. Furthermore, Ball has been transparent about the specific outcomes it seeks through its lobbying efforts, such as achieving "a 90% collection rate for aluminum cans, bottles, and cups by 2030," supporting "well-designed DRS schemes with all beverages in scope," and advocating for strong clean energy standards to reduce carbon emissions. These disclosures illustrate Ball Corporation's comprehensive approach to climate lobbying transparency.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Ball Corporation demonstrates a strong governance process for climate lobbying alignment. The company explicitly states its commitment to align its climate change lobbying with the goal of restricting global temperature rise to 1.5°C, noting that "Ball's CEO is engaged at board level for oversight of our climate change and lobbying advocacy, with the Chief Sustainability Officer responsible for its day-to-day implementation." This indicates clear accountability structures for climate lobbying oversight. Furthermore, Ball Corporation regularly reviews its "advocacy positions, policy objectives, memberships, associations, alliances and coalitions against our climate transition plan," showcasing a defined process for monitoring and managing alignment. The company also emphasizes transparency in its advocacy efforts, stating, "We believe that companies need to align their advocacy efforts with their climate transition plans and, in doing so, are guided by the global Standard On Responsible Corporate Climate Lobbying." Additionally, Ball Corporation actively engages in aligning its memberships and associations with its climate goals, as evidenced by its participation in organizations such as the Aluminium Stewardship Initiative and the First Movers Coalition, which promote circularity and decarbonization. While the evidence does not mention a detailed lobbying audit or comprehensive review of indirect lobbying efforts, the governance mechanisms described reflect a robust approach to ensuring alignment of climate lobbying activities.	3