Sherwin-Williams Co/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Sherwin-Williams discloses that “Sherwin-Williams has a cross-functional, senior management Sustainability Steering Committee … [which] establishes policy for the Company with regards to our sustainability programs, including climate change,” and states that this body, together with several technical workgroups, is responsible for “process(es) … to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan.” This indicates that a formal committee at senior-management level oversees how the company’s advocacy and other external interactions are aligned with its climate strategy, which is further reinforced by a “public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” The company also acknowledges indirect lobbying by noting that “we are members of the American Coatings Association, who has represented our interests during the development of regulations,” and that it “provide[s] feedback as appropriate,” showing some recognition of how trade-association advocacy connects to its own climate objectives. However, the disclosure does not explain how the Steering Committee monitors or reviews specific lobbying positions, gives no criteria for assessing the climate-policy alignment of the American Coatings Association or other associations, and offers no description of escalation procedures, corrective action, or public reporting on lobbying alignment. There is likewise no dedicated audit or detailed review of either direct or indirect climate-related lobbying. Overall, the company reveals a governance mechanism and a stated alignment commitment, but the processes and monitoring steps for ensuring lobbying consistency with climate goals are only briefly described and lack depth or transparency. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Sherwin-Williams discloses that “Sherwin-Williams has a cross-functional, senior management Sustainability Steering Committee … [which] establishes policy for the Company with regards to our sustainability programs, including climate change,” and states that this body, together with several technical workgroups, is responsible for “process(es) … to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan.” This indicates that a formal committee at senior-management level oversees how the company’s advocacy and other external interactions are aligned with its climate strategy, which is further reinforced by a “public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” The company also acknowledges indirect lobbying by noting that “we are members of the American Coatings Association, who has represented our interests during the development of regulations,” and that it “provide[s] feedback as appropriate,” showing some recognition of how trade-association advocacy connects to its own climate objectives. However, the disclosure does not explain how the Steering Committee monitors or reviews specific lobbying positions, gives no criteria for assessing the climate-policy alignment of the American Coatings Association or other associations, and offers no description of escalation procedures, corrective action, or public reporting on lobbying alignment. There is likewise no dedicated audit or detailed review of either direct or indirect climate-related lobbying. Overall, the company reveals a governance mechanism and a stated alignment commitment, but the processes and monitoring steps for ensuring lobbying consistency with climate goals are only briefly described and lack depth or transparency.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Sherwin-Williams provides only limited insight into its climate-related lobbying. The company notes that it "participates in various regional and industry trade associations," citing membership of the American Coatings Association and the European Council of the Paint, Printing Ink and Artists’ Colours Industry, which confirms an indirect mechanism of engagement but does not identify any specific government bodies or decision-makers it seeks to influence. It discloses no concrete climate policies, laws or regulations that it has lobbied for or against, and it offers no explanation of the legislative or regulatory outcomes it wishes to achieve through its association work. As a result, the disclosure does not allow readers to understand what climate policy positions the company promotes, how it seeks to promote them, or to whom those efforts are directed.	D