Air Products and Chemicals Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Air Products and Chemicals Inc provides an unusually full picture of its climate-related lobbying. It names a broad slate of specific measures it has worked on, including the IRA section 45V hydrogen tax credit, the U.S. EPA Greenhouse Gas Reporting Rule (40 CFR Part 98), California’s Mandatory Reporting of Greenhouse Gas Emissions regulation, the UK Renewables Obligation Scheme and Energy Market Reform, EU emissions-trading allocation rules, and other national reporting rules in Ontario and Alberta. The company also spells out how and where it lobbies: it gave formal testimony at the IRS Building, “met directly with EU policy-makers,” “periodically meets directly with regulatory staff, participates in public regulatory workshops and submits formal and informal comments,” and engages “through the vehicles of the European Industrial Gas Association” as well as direct consultations with the UK Government, U.S. Treasury, IRS and EPA. Finally, it is explicit about the precise outcomes it pursues, calling for “strict standards for the 45V hydrogen tax credit” based on “hourly matching of electricity with hydrogen production starting in 2028,” “incrementality of clean electricity starting Day One,” and “deliverability” rules, opposing any grandfathering of existing projects, seeking to “more clearly codify the rules for calculating the carbon intensity of hydrogen within the IRA,” pushing for “comparable treatment … to all producers” under EU emissions-trading free-allowance rules, and asking that reporting methodologies “define reasonable measurement requirements, accuracy expectations and alternatives to address missing data points.” By identifying the policies, the mechanisms and targets of its engagement, and the concrete policy changes it seeks, the company demonstrates a very high level of transparency in its climate-policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Air Products discloses structured efforts to align its direct engagement with climate goals—“regional environmental specialists and Government Relations Team members provide expertise for matters related to greenhouse gases and climate change including internal policy development, regulations, and legislation,” and these experts “share information and best practices across regions to promote consistent approaches to climate change developments”—and it has the Corporate Governance and Nominating Committee of the Board “monitor[ing] the Company’s political activities through annual reports” from management and enforces its “Code of Conduct and Business Ethics” across the organization. However, the company does not disclose a formal climate‐lobbying review or sign‐off procedure, makes no reference to evaluating or exiting industry associations whose positions conflict with its climate strategy, and lacks a current public commitment to align its engagement with the Paris Agreement, noting only that “we plan to have one in the next two years.”	2