First Solar Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive First Solar Inc. demonstrates a high level of transparency in detailing its climate-policy lobbying. It cites numerous identifiable measures it has engaged on, including the U.S. Inflation Reduction Act and its embedded Solar Energy Manufacturing for America Act, the extension of the U.S. Section 201 solar tariffs, India’s Production Linked Incentive Scheme for PV manufacturing, the EU Net-Zero Industry Act and wider ‘Fit for 55’ package, EU Eco-Design and Energy-Labelling rules for PV, state-level Renewable Portfolio Standards, and several recycling or circular-economy proposals for solar modules. The company is equally explicit about how it lobbies: it notes that it “submitted public comments on the proposed regulation in November 2022,” “worked directly with the State Government of Tamil Nadu,” “engaged EU and national regulators both directly and through trade associations,” and “supported it both directly and indirectly as a member of Solar Power Europe (SPE) … as well as the European Solar Manufacturing Council (ESMC).” It also describes mechanisms such as regular meetings with legislators and regulators, testimony in integrated-resource-planning proceedings, and contributions made through the First Solar Political Action Committee. Finally, the firm spells out the concrete outcomes it seeks: securing “additional budgetary support” under India’s PLI scheme, achieving “mandatory high-value recycling of PV waste streams,” winning advanced-manufacturing tax credits under Section 45X, “closing Buy American loopholes,” extending the Section 201 tariffs “without a bifacial exemption,” and raising renewable-energy targets in the EU and multiple U.S. states. By naming the specific policies, the methods and targets of engagement, and the precise changes it is advocating, First Solar provides comprehensive visibility into its climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate First Solar discloses a defined governance structure for its political and public policy activities, with oversight from its Nominating and Governance Committee, the CEO and a cross-functional ESG Steering Committee. For example, “the Public Affairs Department reports annually to the Nominating and Governance Committee … on significant policies and practices concerning political contributions, payments to trade associations which may be used for political purposes, and political activity priorities in light of the Company’s public policy objectives,” and “First Solar’s VP of Global Policy, Marketing and Sustainability is part of the cross-functional ESG taskforce … responsible for driving the company’s approach to Responsible Solar, including public policy in alignment with the goals of the Paris Agreement.” These disclosures show named individuals and committees that oversee political engagement and a stated commitment to aligning public policy work with climate objectives. However, the company does not disclose any formal process for reviewing or managing its lobbying positions against its climate strategy, no audit or assessment of climate-related lobbying alignment, and no procedures for engaging with or exiting trade associations whose policy positions conflict with its climate goals. 2