Ardagh Metal Packaging SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Ardagh Metal Packaging has implemented a framework tying its climate engagement to its broader environmental policy, stating “we have numerous processes in place to make sure that our multiple climate engagement activities across our business are in line with our climate change strategy” through its “group-wide Code of Conduct” and embedded Environmental Policy. The company explains it “actively engage[s] with trade associations” and ensures “all our concerns and aspirations, which are aligned in and with our climate change strategy, are identified and taken into account,” relaying “immediate updates regarding changes in technical standards, policies and news” via “reviews, audits, training and reporting, assuring compliance by our global team.” This demonstrates concrete mechanisms to align both direct engagement with policymakers and indirect lobbying through associations. However, the company does not disclose a specific individual or committee responsible for overseeing lobbying alignment, nor does it describe a tailored sign-off or board-level review of policy advocacy efforts, and we found no dedicated public report or audit focused on climate-lobbying alignment. As such, while alignment processes are evident, the governance structure for lobbying remains broadly defined within its sustainability program rather than focused on targeted oversight of lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Ardagh Metal Packaging has implemented a framework tying its climate engagement to its broader environmental policy, stating “we have numerous processes in place to make sure that our multiple climate engagement activities across our business are in line with our climate change strategy” through its “group-wide Code of Conduct” and embedded Environmental Policy. The company explains it “actively engage[s] with trade associations” and ensures “all our concerns and aspirations, which are aligned in and with our climate change strategy, are identified and taken into account,” relaying “immediate updates regarding changes in technical standards, policies and news” via “reviews, audits, training and reporting, assuring compliance by our global team.” This demonstrates concrete mechanisms to align both direct engagement with policymakers and indirect lobbying through associations. However, the company does not disclose a specific individual or committee responsible for overseeing lobbying alignment, nor does it describe a tailored sign-off or board-level review of policy advocacy efforts, and we found no dedicated public report or audit focused on climate-lobbying alignment. As such, while alignment processes are evident, the governance structure for lobbying remains broadly defined within its sustainability program rather than focused on targeted oversight of lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Ardagh Metal Packaging provides a limited but discernible view of its climate-related lobbying. It names two concrete policy areas it engages on—“the recast of the Packaging and Packaging Waste Directive” in the EU and support for “carbon taxes” in the United Kingdom—thereby giving some clarity about the measures it seeks to influence. The company also outlines its methods, noting that it "engage[s] directly and/or through our industry association with policy makers" and that it will "organize meetings and provide tours of our production facilities … to present our policy proposals," which illustrates the use of meetings, facility tours and trade-association channels, although it does not identify the specific governmental bodies or officials approached. In terms of objectives, it declares a general "position on the policy: Support with no exceptions" for carbon taxes and expresses broad backing for higher recycling rates, yet it stops short of defining concrete legislative outcomes, timelines or amendments it is pursuing. Taken together, the disclosure offers some insight into policies, mechanisms and intentions, but important details—particularly the exact targets of its lobbying and the specific outcomes sought—remain opaque.	D