First Solar Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	First Solar Inc has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly named specific climate-related policies it has engaged with, such as the Inflation Reduction Act (IRA), the EU Green Deal, the Fit for 55 draft legislation, the Section 201 Tariffs, and the Solar Energy Manufacturing for America Act. It has also disclosed its involvement in state-level clean energy generation policies and international initiatives like the European Commission Circular Economy Package. These disclosures include detailed descriptions of the policies, their geographical scope, and their alignment with broader climate goals, such as the Paris Agreement. First Solar has provided extensive details about its lobbying mechanisms, including direct engagement through comments, testimony, and meetings with legislators, regulators, and staff, as well as indirect engagement through trade associations like the Solar Energy Manufacturing for America (SEMA) coalition and Solar Power Europe. The company has also disclosed its participation in structured initiatives like the Joint Mission Group on Eco-Design and Energy Labeling under the European Commission. Specific targets of its lobbying efforts include the U.S. government, the European Commission, and state legislatures in multiple U.S. states, as well as international bodies like the Ministry of New and Renewable Energy (MNRE) in India. Furthermore, First Solar has been transparent about the specific outcomes it seeks through its lobbying efforts. These include advocating for incentives for domestic manufacturing, closing Buy American loopholes, tariff reform, and the development of Eco-Design and Energy Labeling criteria for PV modules. The company has also supported expanded Renewable Portfolio Standards (RPSs), clean energy procurement requirements, and fiscal incentives for domestic PV module manufacturing. These desired outcomes are explicitly linked to broader climate objectives, such as reducing carbon footprints, advancing U.S. energy independence, and aligning with the Paris Agreement. This level of detail demonstrates First Solar's commitment to transparency and its alignment with climate transition goals.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	First Solar demonstrates a defined governance process for climate lobbying alignment, including monitoring details and responsible parties. The company explicitly mentions aligning its indirect lobbying efforts, including direct lobbying activities and lobbying conducted through trade associations, stating, "First Solar participates in the political process to help shape public policy, legislation and other governmental actions that are consistent with First Solar's business objectives and values." The governance mechanisms include oversight by the VP of Global Policy, Marketing, and Sustainability, who is part of the cross-functional ESG taskforce responsible for driving the company's approach to Responsible Solar, including public policy alignment with the Paris Agreement. The company describes a policy to ensure alignment of climate lobbying activities and a process for monitoring these activities. It states, "Updates on ESG focus areas including public policy are provided on a biannual or more frequent basis to the Board's Nominating and Governance committee which reviews the Company's ESG strategy, policies and initiatives." Additionally, public policy and advocacy updates are provided quarterly to the full Board of Directors, ensuring comprehensive oversight. First Solar has identified the individuals and groups responsible for overseeing climate lobbying alignment. The ESG Steering Committee, led by the CEO and consisting of the Executive Leadership Team, provides updates to the Nominating and Governance Committee on a biannual or more frequent basis. The company also engages with external stakeholders, such as trade associations, to influence policy positions consistent with its environmental commitments, stating, "We work closely with their research arm (Clean Energy Buyers Institute) to raise awareness about the need to drive down the embodied carbon of solar." This indicates strong governance with clear accountability structures and monitoring mechanisms in place.	3