Eastman Chemical Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Eastman Chemical has implemented several governance mechanisms to align its policy advocacy with its climate strategy, but it does not disclose detailed procedures for monitoring or managing climate-specific lobbying activities. Direct lobbying is centralized, as “employees of Eastman's Government Affairs Department are authorized to engage in federal, state, local and foreign lobbying activities on behalf of Eastman. No other employee is authorized to approve lobbying activities on behalf of Eastman unless such approval is granted by the Government Affairs Department,” ensuring single-point oversight. Indirect lobbying is subject to review, since “proposed memberships in and contributions to trade and business associations are reviewed by Eastman's Government Affairs Department and such memberships are reported annually to Eastman's Board of Directors and its Environmental, Safety and Sustainability Committee,” providing board-level visibility over association engagements. Eastman further commits that its engagement activities are aligned with global goals, confirming it has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” Climate alignment is overseen by a Sustainability Council “chaired by the company’s chief sustainability officer” and including its Chief Legal Officer, which “reviewed and approved Eastman’s public commitments and position on climate change,” and “ensures that Eastman’s engagement activities are consistent with our overall climate change strategy.” Despite these structures, the company does not disclose any dedicated climate-lobbying audit or specific monitoring process for policy positions, nor does it specify how it addresses conflicts between association stances and its climate objectives. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Eastman Chemical has implemented several governance mechanisms to align its policy advocacy with its climate strategy, but it does not disclose detailed procedures for monitoring or managing climate-specific lobbying activities. Direct lobbying is centralized, as “employees of Eastman's Government Affairs Department are authorized to engage in federal, state, local and foreign lobbying activities on behalf of Eastman. No other employee is authorized to approve lobbying activities on behalf of Eastman unless such approval is granted by the Government Affairs Department,” ensuring single-point oversight. Indirect lobbying is subject to review, since “proposed memberships in and contributions to trade and business associations are reviewed by Eastman's Government Affairs Department and such memberships are reported annually to Eastman's Board of Directors and its Environmental, Safety and Sustainability Committee,” providing board-level visibility over association engagements. Eastman further commits that its engagement activities are aligned with global goals, confirming it has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” Climate alignment is overseen by a Sustainability Council “chaired by the company’s chief sustainability officer” and including its Chief Legal Officer, which “reviewed and approved Eastman’s public commitments and position on climate change,” and “ensures that Eastman’s engagement activities are consistent with our overall climate change strategy.” Despite these structures, the company does not disclose any dedicated climate-lobbying audit or specific monitoring process for policy positions, nor does it specify how it addresses conflicts between association stances and its climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Eastman Chemical is highly transparent about its climate-policy lobbying. It names multiple concrete measures it engages on, including the “Proposed SEC Climate Disclosure Rule,” the “Inflation Reduction Act,” the EU “Green Deal,” the EU and U.K. Emissions Trading Systems, and circular-economy and clean-energy definitions in U.S. and European legislation. The company also spells out how and where it seeks to influence these proposals: it “engage[s] with the US Department of Energy (DOE), Oak Ridge National Laboratory, the National Renewable Energy Laboratory, and Lawrence Berkeley National Laboratory and the US EPA,” “participate[s] through trade associations in providing feedback on the proposal during the public comment period,” and its “government affairs team interacts directly with legislators.” By identifying both direct meetings and written submissions as well as indirect channels through industry bodies and consultants, and by naming specific targets such as the DOE, EPA and SEC rule-makers, Eastman clarifies the full range of its lobbying mechanisms. The company also articulates the concrete outcomes it is pursuing, for example advocating for “an inclusive suite of definitions that allows for material-to-material molecular recycling technologies and mass balance accounting for purposes of recycled content,” “broad definitions of clean energy,” “comparable climate-related disclosures with a flexible, materiality-driven framework, an appropriate scope, and reasonable timelines,” and legislation that “encourage[s] additional use of efficient combined heat and power.” These detailed positions, coupled with clear descriptions of methods and targets, demonstrate a comprehensive level of transparency around the company’s climate lobbying activities.	A