ArcelorMittal SA

ArcelorMittal discloses an integrated governance framework that explicitly links its climate objectives with the oversight, monitoring and correction of both direct and trade-association lobbying activities. The company states that it is "committed to conducting all its direct and indirect policy lobbying and advocacy work in line with the Paris Agreement" and has established clear escalation measures "including direct communication requesting further alignment...ringfenc[ing] our financial contribution... and ceasing our membership," demonstrating a mechanism for enforcing alignment. Oversight is anchored at board level where "The Sustainability Committee of the Board meets quarterly to review Sustainability matters of the company. This includes high level policy asks," while climate-specific policy engagement is further scrutinised by the executive-level Climate Change Committee, the ARCGS Committee and the "Group Climate Council... [whose] members include VP government affairs." The company also provides public, systematic reviews of lobbying alignment: "In January 2022, ArcelorMittal published its second Climate Advocacy Alignment report which maps the policy positions of the 61 associations," following earlier "periodic assessment of industry associations in 2020 and 2022." These published reports cover indirect lobbying and drive follow-up action, as the company notes that it is "continu[ing] to engage with industry associations that were found not to be fully aligned... until the publication of our next report." Direct lobbying is governed through internal principles and sign-off processes led by "our Government Affairs teams," and every two years the company performs "an assessment of advocacy engagements with trade associations and other organizations to assess their alignment." This suite of public reporting, recurring assessments, board-level oversight and defined corrective measures indicates a comprehensive governance system; the only area the company does not elaborate on is how individual direct-lobbying campaigns are evaluated in real time, but the existing disclosures nonetheless show strong, transparent and proactive control of climate-related lobbying.