Axalta Coating Systems Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Axalta provides a basic picture of how it seeks to influence climate-related policy but leaves many important details undisclosed. The company explains that it works mainly through trade bodies, citing participation in ACA’s Paint the Hill Days, membership of the American Chemistry Council and the American Coatings Association, and the practice of “commenting on draft legislation” and “building relationships with key legislators and regulators at the local, state, and federal level,” thereby revealing multiple lobbying mechanisms as well as the broad target of U.S. Representatives, Senators and regulatory agencies. However, it never names a specific piece of climate legislation or regulation it has tried to influence, describing its activity only in broad terms such as “environmental regulations and sustainability.” Likewise, its description of desired outcomes remains general—“Advocating for sustainable policies and sharing the successes of our company and the industry are at the core of Axalta’s government affairs efforts”—without stating any concrete policy amendments, targets or timelines it is pursuing. As a result, while the company is reasonably clear about the channels it uses, its disclosures offer only limited transparency on the particular policies and outcomes it seeks.	1

Lobbying Governance

Overall Assessment	Comment	Score
None	Axalta’s disclosures indicate that it does not engage in direct monetary lobbying or political contributions, noting that “Axalta does not make any political contributions in the United States or use any corporate funds for lobbying. We also do not have a political action committee (PAC),” and instead focuses on relationship-building and advocacy through industry associations. Although the Board’s Environment, Health, Safety & Sustainability Committee and Nominating & Corporate Governance Committee oversee broad ESG matters—“oversight of the Company’s policies, performance, strategy and compliance matters related to environment, health, safety, human rights and sustainability” and “regularly discusses the Company’s ESG practices and disclosures”—the company does not disclose any specific policy, process or individual oversight for its lobbying activities, whether direct or through associations. We found no evidence of a requirement to align external engagement with its climate commitments, nor any commitment to conduct these activities in line with the goals of the Paris Agreement, as noted in its response, “No, and we do not plan to have one in the next two years.”	0