Delta Air Lines Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Delta Air Lines discloses a detailed and multi-layered governance system that specifically governs both its direct and indirect climate-lobbying activities. The company publishes an annual Climate Lobbying Report which details the companys global advocacy activities and policy engagementsboth direct and indirectthat support and complement our Paris Agreement-aligned climate goals and within which this section of the report also assesses these climate lobbying activities for alignment with our net-zero climate goals and policy principles. Oversight responsibilities are clearly assigned: Management of our overarching advocacy and regulatory compliance activities is the responsibility of our Executive Vice President and Chief Legal Officer in conjunction with our Senior Vice President, Government Affairs, and our Vice President, State and Local Government Affairs, while at the board level the Corporate Governance Committee of the Board also receives formal reports on our political activities and reviews and approved the Climate Lobbying Report. Day-to-day leadership is provided by the new role of Vice President, Government Affairs Sustainability ensuring alignment between the companys climate goals and its climate lobbying activities. The company explains that it periodically assess[es] the alignment of Delta and Monroes trade associations climate change positions with our own In 2023, we assessed the activities of key associations, including IATA, A4A, the Business Roundtable and American Fuel and Petrochemical Manufacturers, and elaborates a two-step methodology that examines both stated positions and specific lobbying actions. Delta also notes that where misalignment arises we have in the past taken and may in the future take independent actions to mitigate risks an associations actions may present to our strategy. This combination of a publicly available alignment assessment, explicit processes for reviewing trade-association positions, dedicated management roles, and routine board oversight indicates a comprehensive and transparent governance framework for climate-lobbying alignment. We found no evidence that any required element of monitoring, oversight or disclosure is missing from the companys public materials, which indicates very strong governance. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Delta Air Lines discloses a detailed and multi-layered governance system that specifically governs both its direct and indirect climate-lobbying activities. The company publishes an annual Climate Lobbying Report which details the companys global advocacy activities and policy engagementsboth direct and indirectthat support and complement our Paris Agreement-aligned climate goals and within which this section of the report also assesses these climate lobbying activities for alignment with our net-zero climate goals and policy principles. Oversight responsibilities are clearly assigned: Management of our overarching advocacy and regulatory compliance activities is the responsibility of our Executive Vice President and Chief Legal Officer in conjunction with our Senior Vice President, Government Affairs, and our Vice President, State and Local Government Affairs, while at the board level the Corporate Governance Committee of the Board also receives formal reports on our political activities and reviews and approved the Climate Lobbying Report. Day-to-day leadership is provided by the new role of Vice President, Government Affairs Sustainability ensuring alignment between the companys climate goals and its climate lobbying activities. The company explains that it periodically assess[es] the alignment of Delta and Monroes trade associations climate change positions with our own In 2023, we assessed the activities of key associations, including IATA, A4A, the Business Roundtable and American Fuel and Petrochemical Manufacturers, and elaborates a two-step methodology that examines both stated positions and specific lobbying actions. Delta also notes that where misalignment arises we have in the past taken and may in the future take independent actions to mitigate risks an associations actions may present to our strategy. This combination of a publicly available alignment assessment, explicit processes for reviewing trade-association positions, dedicated management roles, and routine board oversight indicates a comprehensive and transparent governance framework for climate-lobbying alignment. We found no evidence that any required element of monitoring, oversight or disclosure is missing from the companys public materials, which indicates very strong governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Delta Air Lines discloses climate-related lobbying in a highly detailed and specific manner. It names a wide range of concrete measures it engages on, including federal bills such as the Sustainable Skies Act, the Aviation Emissions Reduction Opportunity Act, SAF-related provisions of the Inflation Reduction Act and earlier Build Back Better package, state incentives like Minnesota’s SAF tax credit and Washington’s Low Carbon Fuel Standard, international rules such as ICAO’s CORSIA baseline and long-term net-zero goal, and the EU’s ReFuelEU SAF mandate. The company also explains exactly how it tries to influence these measures: its Government Affairs team meets policymakers in Washington, D.C. and key states, files formal comments with the U.S. Treasury, IRS and EPA, submits letters of support for grant applicants, delivers state-house testimony, and works through trade associations (A4A, IATA) and coalitions it helped found, such as “Americans for Clean Aviation Fuels,” to lobby federal, state, EU, UK and ICAO decision-makers. Delta is equally explicit about what it wants to achieve. It seeks “performance-based, feedstock- and technology-neutral incentives” and tax credits to make SAF cost-competitive, advocates that 10 % of its jet fuel be SAF by 2030, calls for increased funding for the FAA CLEEN and ASCENT programmes, presses to keep the CORSIA baseline at 100 % of 2019 levels and to exclude extra-European flights from the EU ETS, and supports reforms to the U.S. Renewable Fuel Standard to cap RIN prices. By providing clear policy references, detailing the instruments and targets of its advocacy, and spelling out concrete legislative changes and quantitative goals, Delta demonstrates a comprehensive level of transparency around its climate-policy lobbying activities.	A