Eastman Chemical Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Eastman Chemical Company has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly identified specific climate-related policies it has engaged with, such as the "SEC's Climate Disclosure Proposal," "U.S. and EU climate-related policies such as the Inflation Reduction Act and EU Green Deal," and its efforts to ensure "broad definitions of clean energy are included in climate change legislation, regulations or policies." Eastman has also provided detailed information about its lobbying mechanisms, including direct engagement with policymakers, participation in trade associations like the American Chemistry Council and the Center for Climate & Energy Solutions, and collaboration with entities such as the U.S. Department of Energy (DOE) and the Environmental Protection Agency (EPA). Furthermore, the company has been transparent about the specific outcomes it seeks, such as advocating for "material-to-material molecular recycling technologies and mass balance accounting for recycled content," supporting "more transparent and comparable climate-related disclosures," and promoting "legislation and regulations that encourage additional use of efficient combined heat and power to reduce power demand from less efficient, traditional power generation plants." These disclosures collectively illustrate Eastman's commitment to providing a clear and detailed account of its climate lobbying efforts and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Eastman demonstrates a defined governance process for climate lobbying, as evidenced by the Sustainability Council chaired by the company's "chief sustainability officer," which is "responsible for Eastman's overall climate change strategy" and includes "Eastman's Chief Legal Officer who is responsible for government affairs among other areas of the company." This council has "reviewed and approved Eastman's public commitments and position on climate change," highlighting a mechanism to align engagement activities with the company's climate strategy. In addition, Eastman states that it "supports legislative proposals to improve energy efficiency and/or promote the increased use of materials that enable renewable energy, energy efficiency, etc." and engages in policy advocacy through trade associations, reaffirming its commitment to the goals of the Paris Agreement. While the evidence does not disclose a detailed monitoring or auditing process ensuring comprehensive alignment of indirect lobbying with these goals, Eastman's identification of responsible parties and stated processes for managing lobbying indicate strong governance.	3