Coca-Cola Co/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	The Coca-Cola Company provides an unusually detailed view of its climate-related lobbying. It identifies a wide range of specific policy files it has worked on, including the "US Nationally Determined Contribution (NDC)", the Colorado law establishing the first statewide Extended Producer Responsibility (EPR) programme, deliberations on the "UN legally binding treaty to end plastic pollution", the Montreal Protocol and EU F-gas legislation, and the EU Code of Conduct on Responsible Food Business and Marketing Practices. The company is equally explicit about how and where it lobbies: it describes direct advocacy with the Biden Administration through coalitions led by We Mean Business and Ceres, states that it wrote "a letter to the U.S. Chamber of Commerce" urging climate-policy alignment, records meetings with “European Parliamentary Environment Committee Chair Pascal Canfin”, and explains that "a third way is via trade associations… [and] a fourth way is direct advocacy"; it also lists indirect channels such as the Consumer Goods Forum, the Business Roundtable, the Clean Energy Buyers Association and its role as “Co-Chair of the Business Coalition for a Global Plastics Treaty”. Finally, Coca-Cola spells out the outcomes it seeks: it pressed for a "science-based greenhouse gas emissions reduction target of at least 50 % below 2005 levels by 2030" for the United States, supports "well-designed Extended Producer Responsibility (EPR) schemes" worldwide to raise recycling rates, backs binding global rules to curb plastic production and set harmonised recycling standards, and promotes the phase-out of HFCs through "HFC-free refrigeration technologies". By clearly naming the policies, disclosing the specific mechanisms and policymaker targets, and articulating the concrete regulatory changes and environmental objectives it is pursuing, the company demonstrates a comprehensive level of transparency around its climate-policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Overall, The Coca-Cola Company has established board-level oversight of its public policy and lobbying activities, with the Corporate Governance and Sustainability Committee—and the ESG and Public Policy Committee—bearing “primary responsibility for overseeing the company’s sustainability strategies and initiatives” and conducting at least annual reviews of its “public policy agenda, its position on significant public policy matters, political contributions and lobbying activities,” while the North America Operating Unit Vice President of Public Policy, Federal Government Relations & Political Engagement, together with the Senior Vice President & Chief of Public Affairs, Communications and Sustainability and the Legal Department, manage and review all political engagement. However, although these committees “assess a range of issues relevant to environmental trends” and climate-related risks, the company does not disclose any policy or formal process to ensure that its direct or indirect lobbying is aligned with its science-based emissions targets, and it explicitly states that it has “no, and we do not plan to have one in the next two years” regarding a commitment to conduct engagement in line with the Paris Agreement. The company also provides no evidence of a dedicated climate-lobbying audit or mechanisms to monitor the positions of trade associations against its climate strategy, indicating that while general governance and oversight are in place, specific governance for climate lobbying alignment is not demonstrated.	2