Direct Lobbying Transparency
| Overall Assessment | Comment | Score |
|---|---|---|
| Comprehensive | PayPal provides a high level of transparency around its climate-policy lobbying. It names multiple specific measures it has engaged on, including the “March 15 2021 SEC Statement Welcoming Public Input on Climate Change Disclosures,” the SEC’s proposed rule “File Number S7-10-22: The Enhancement and Standardization of Climate-Related Disclosures for Investors,” letters supporting “cap-and-invest legislation in Oregon and Washington,” and advocacy for “robust building decarbonization policies in the Western U.S.” The company also explains exactly how it lobbied and who was targeted: it “submitted public comments” to the SEC, “signed on to a letter with over 50 other businesses and higher education institutions to Governor Newsom of California and the California Energy Commission,” and “signed on to a letter to administrative and legislative leaders in California, Oregon and Washington,” thereby outlining both the direct and coalition-based mechanisms it used and clearly identifying the policymaking bodies addressed. Finally, PayPal is explicit about the outcomes it seeks. For federal disclosure rules it presses for “support of mandatory reporting,” alignment with “established standards,” and “flexibility and phased-in implementation”; for state building policies it urges “energy efficiency programs,” “building energy benchmarking programs,” and “performance standards for new and existing buildings”; and for regional carbon policy it calls for an “expansion of the programs to scale up efforts to reduce greenhouse gas (GHG) emissions across the region.” By detailing the policies, the methods and targets of engagement, and the precise changes it wants to see, the company demonstrates comprehensive transparency in its climate-related lobbying. | 4 |