Archer-Daniels-Midland Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Archer-Daniels-Midland provides a detailed list of the climate-related laws and regulations it seeks to influence, naming the U.S. Renewable Fuel Standard, Sustainable Aviation Fuel provisions, and Carbon Capture and Sequestration rules, Canada’s Clean Fuel Regulations, and several EU measures such as RED II/III, ReFuelEU Aviation, FuelEU Maritime, and vehicle CO2 standards. This demonstrates strong transparency on the policies covered. The company is less specific about how it tries to influence those measures: it states that it lobbies directly with U.S. policymakers and indirectly through trade associations in both the United States and the European Union, but it does not identify the particular agencies, ministries, or legislators it contacts, nor does it describe concrete actions such as written submissions, meetings, or testimony. Likewise, while ADM indicates broad support for the named policies and alignment with the Paris Agreement, it does not spell out the precise changes or outcomes it is advocating—such as specific amendments, targets, or timelines—leaving the objectives of its lobbying only generally defined. Overall, the disclosure is comprehensive on the policies engaged but comparatively limited on lobbying methods and intended policy outcomes.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Archer-Daniels-Midland provides limited insight into how it governs climate-related lobbying. It notes that “the governance of this policy has been reviewed by the company´s Sustainability & Corporate Responsibility Committee of the ADM Board of Directors,” and confirms that it maintains “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” The company also explains that “our sustainability efforts are overseen by our Board of Directors, in particular a dedicated Sustainability and Corporate Responsibility Committee, and led by our Chief Sustainability Officer.” These statements show high-level Board involvement and a Paris-aligned commitment covering its external engagement. Nevertheless, the disclosures do not describe any concrete procedures for monitoring or managing lobbying activities, give no examples of reviewing trade-association positions, and do not assign specific accountability for ensuring that direct or indirect lobbying is aligned with climate goals. Consequently, the publicly available information points to only a basic governance commitment rather than a defined lobbying-governance framework.	1