Vistra Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Vistra Corp provides an exceptionally detailed window into its climate-policy advocacy. It names multiple concrete measures it engages on, including the Climate Leadership Council’s framework for a “national carbon fee and dividend approach with a border tax adjustment,” the Council’s Bipartisan Carbon Roadmap that would “cut U.S. CO2 emissions in half by 2035,” the Illinois Coal-to-Solar & Energy Storage Initiative contained in the 2021 Energy Transition Act, and its participation in emissions trading schemes such as California CaT, Massachusetts ETS and RGGI. The company also outlines how it seeks to influence these measures: it takes part in meetings, submits written letters, and holds regular discussions with regulators and policymakers, while indirectly lobbying through bodies such as the Climate Leadership Council, Americans for Carbon Dividends and the Zero Emissions Transportation Association; it specifically identifies targets including the Federal Energy Regulatory Commission, state and federal government officials, and market operators PJM and ISO-NE. Finally, Vistra is explicit about the results it wants, backing “a consistently applied national carbon fee and dividend approach,” supporting “100% electric vehicle sales by 2030,” and advocating for legislation that allows up to 300 MW of solar and 150 MW of battery storage on retired coal sites in Illinois, all aimed at accelerating market-based decarbonisation while safeguarding reliability and affordability. This level of specificity across policies, mechanisms and desired outcomes demonstrates a comprehensive degree of transparency in the company’s climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Vistra has established a formal review process to align its indirect lobbying efforts with its climate strategy, committing to “review all its memberships with trade groups, associations, and other third-party organizations” annually “to discern whether their positions are materially inconsistent with Vistra’s views” and pledging that if its efforts “to align our positions” within those organizations fail, it “may withdraw from or otherwise disassociate” from the group. This indirect lobbying governance is overseen by a clearly designated leader and accountability forums: the Chief Strategy & Sustainability Officer “directly reporting to the CEO” presents to the Sustainability and Risk Committee of the board “at least quarterly,” and the Executive, Commitments, and Risk Committees provide daily oversight of environmental principles. We found no evidence of a separate governance process addressing the company’s direct lobbying activities or a distinct audit or report evaluating climate-related lobbying alignment.	2