Graphic Packaging Holding Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Graphic Packaging Holding Co 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, including the Extended Producer Responsibility (EPR) frameworks in Europe and North America, the Packaging and Packaging Waste regulation under the European Green Deal and Circular Economy Action Plan, and the UK's new EPR scheme set to be implemented in 2024. It has provided detailed descriptions of its positions, such as opposing EPR frameworks that do not factor in recovery rates and advocating for proportionate requirements for fiber-based packaging. The company has also disclosed its lobbying mechanisms and targets in detail. It engages directly with policymakers, such as Members of the European Parliament (MEPs), and participates in trade associations like the American Forest and Paper Association (AF&PA). It has described its methods, including submitting position papers, engaging in discussions with policymakers, and advocating for harmonization in collection, sorting, and recycling of packaging across Europe. Additionally, it funds a political action committee (GPI-PAC) to support candidates aligned with its business interests, ensuring compliance with federal and state election laws. These mechanisms and targets are clearly identified and linked to specific climate-related policies. Furthermore, the company has been transparent about the specific policy outcomes it seeks. It opposes EPR frameworks that do not account for recovery rates and advocates for "fee structures scaled based on actual material recovery" to encourage the use of highly recovered materials. It also seeks "harmonization in terms of collection, sorting and recycling of packaging across Europe" and questions the environmental benefits of reuse obligations compared to single-use paper solutions. These desired outcomes are clearly articulated and tied to specific policy engagements, demonstrating alignment with its broader sustainability goals.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Graphic Packaging has disclosed a defined governance process to ensure alignment of its climate lobbying activities with its overall climate change strategy. "Graphic Packaging's VP of Government Affairs provides strategic direction and ensures that the direct and indirect activities regarding climate change policies are consistent with the strategy." This indicates a clear policy for alignment and monitoring of lobbying activities. Furthermore, "Graphic Packaging's President and CEO and other members of the Executive Team participate in policy discussions at Federal and State levels," which demonstrates the involvement of responsible parties in overseeing climate lobbying alignment. The strategy is "reviewed formally each year and on an ad hoc basis," providing evidence of ongoing monitoring and management processes. Additionally, the long-range plan, which incorporates environmental and climate change risks and opportunities, is "presented to the Board of Directors for its consideration and approval," further reinforcing the governance structure and oversight mechanisms in place. This indicates strong governance.	3