Cleveland-Cliffs Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Cleveland-Cliffs Inc. indicates that “we have an active government relations department that keeps upper management informed of the climate-related public policy initiatives in which the company and the associations we belong to are engaged,” which allows it to “identify and make any necessary changes to our activities should there be any inconsistencies with our overall policy strategies.” This reflects an internal mechanism to monitor both its direct engagement and its trade association memberships, notably its collaboration with the American Iron and Steel Institute, where Cleveland-Cliffs reports that it is “serving on the AISI committee that advances sustainability in our industry” and works closely to “outline the priorities for AISI’s climate policy.” However, the company acknowledges that it does not have “a public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement” and does not plan to adopt one in the next two years, and it does not name any individual or formal committee—such as a board governance body or a head of government affairs—that oversees climate lobbying alignment. While these disclosures show some governance via the government relations department’s reporting to upper management, the absence of a formal oversight body or named owner of lobbying governance and the lack of a public alignment commitment indicate that more structured climate lobbying governance documentation is unavailable. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Cleveland-Cliffs Inc. indicates that “we have an active government relations department that keeps upper management informed of the climate-related public policy initiatives in which the company and the associations we belong to are engaged,” which allows it to “identify and make any necessary changes to our activities should there be any inconsistencies with our overall policy strategies.” This reflects an internal mechanism to monitor both its direct engagement and its trade association memberships, notably its collaboration with the American Iron and Steel Institute, where Cleveland-Cliffs reports that it is “serving on the AISI committee that advances sustainability in our industry” and works closely to “outline the priorities for AISI’s climate policy.” However, the company acknowledges that it does not have “a public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement” and does not plan to adopt one in the next two years, and it does not name any individual or formal committee—such as a board governance body or a head of government affairs—that oversees climate lobbying alignment. While these disclosures show some governance via the government relations department’s reporting to upper management, the absence of a formal oversight body or named owner of lobbying governance and the lack of a public alignment commitment indicate that more structured climate lobbying governance documentation is unavailable.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Cleveland-Cliffs has been transparent about its climate lobbying activities. It clearly names the specific policies it engaged on—the industrial decarbonization programs funded by the 2021 Infrastructure Investment & Jobs Act, the 2022 Inflation Reduction Act, and reporting under regulation 40 CFR 98—and states its support for a carbon border adjustment program designed to prevent carbon leakage. It spells out a variety of direct and indirect lobbying mechanisms, from hosting visits by the U.S. Secretary of Energy and meetings with U.S. EPA, to supplying emissions data under 40 CFR 98 and participating in industry forums through the American Iron and Steel Institute. For example, the company notes that “we are a proud member of the DOE’s Better Plants program for energy efficiency” and that it “engaged directly with policy makers such as U.S. EPA.” Finally, Cleveland-Cliffs sets out clear policy outcomes it seeks—public policies that incentivize GHG reduction while encouraging domestic steel production, enactment of a carbon border adjustment program, and both public and private investment in sustainable technologies—demonstrating a comprehensive level of transparency around its climate-policy lobbying.	4