International Paper Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	International Paper provides extensive and detailed disclosure of its climate-related lobbying. It identifies a range of concrete policies on which it has actively engaged, including the 2008 Lacey Act and its amendments, the “forest sustainability language included in the United States-Mexico-Canada Agreement (USMCA),” the U.S. Securities and Exchange Commission’s April 2022 proposed climate-disclosure rules, and repeated requests that the U.S. Environmental Protection Agency adopt a policy statement recognising forest biomass as carbon-neutral. The company explains how it lobbies, noting that it "advocate[s] – directly and through our trade associations – at all levels of government, including policymakers and legislators," and listing channels such as legislative hearings, one-on-one meetings, letters and emails, participation in DOE programmes, and work through associations like the American Forest & Paper Association (AF&PA) and the Confederation of European Paper Industries (CEPI). Targets are named explicitly, for example “Congress,” the “U.S. Environmental Protection Agency,” and the Departments of Energy and Agriculture. It is equally clear about the specific outcomes it seeks: ensuring the Lacey Act is fully funded and enforced, having anti-illegal-logging provisions embedded in future trade deals, securing statutory recognition that its manufacturing biomass residuals are carbon-neutral, encouraging federal and state investment in recycling infrastructure while opposing “content requirements, bans or fees on paper products,” and promoting “off-ramps for products that have achieved 65 % recovery rates.” By describing the concrete policies, the precise engagement channels and the explicit legislative or regulatory changes it wants, the company demonstrates a comprehensive level of transparency around its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	International Paper maintains an integrated sustainability governance structure in which a Board-level Public Policy and Environment Committee “reviews environmental, sustainability and social impact issues and risks (including climate change)” and receives biannual updates from the Chief Sustainability Officer, corporate controller and general counsel on “progress on our science-based target and opportunities to advance progress.” At the management level, the company’s Climate Change statement “has been approved by our Global Citizenship, Global Environmental Health & Safety Center of Excellence, Legal and Government Relations departments,” and “all relevant activities are managed centrally” with the statement “revised and updated timely.” The company engages directly with policymakers through its government relations team in Washington, D.C., state capitals and internationally and engages indirectly by participating in trade associations, noting that “our policy positions are generally consistent with the trade associations, coalitions and other organizations in which we participate” and that “we regularly review our needs and perspectives along with those of our trade associations.” However, the company does not disclose a formal individual or committee specifically tasked with reviewing or approving climate-related lobbying activities in line with its climate commitments, nor does it describe a clear process for aligning—and where necessary correcting or exiting—associations whose positions conflict with its climate strategy. We found no evidence of a dedicated climate-lobbying audit or board sign-off on climate advocacy plans, indicating that while robust sustainability oversight exists, explicit governance processes for climate lobbying alignment remain limited.	2