XPO Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	XPO Inc is reasonably clear that it plays virtually no role in climate-related lobbying. It spells out that "it does not participate in direct political activities or make corporate contributions to groups organized under section 501(c)(4) or section 527 of the Internal Revenue Code" and that any limited advocacy is subject to an annual Board-level review of trade-association memberships. By stating outright that it does not lobby on climate policy, the company is transparent about the absence of specific policy engagements and, consequently, of any sought-after policy outcomes. However, beyond noting its decision not to lobby and describing the internal oversight process, the disclosure does not detail why this position was taken, list any climate policies considered, or set out alternative objectives it might pursue through its trade associations. As a result, the company provides a moderate level of transparency: it is explicit about non-engagement and the mechanisms that ensure this stance, but offers limited insight into the rationale or any nuanced policy positions.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	XPO Inc’s disclosures indicate that the company “does not participate in direct political activities” and “does not make corporate contributions to groups organized under section 501(c)(4) or section 527 of the Internal Revenue Code,” underscoring a limited approach to direct lobbying. It further states that it “complies with public reporting requirements and maintains a rigorous oversight process of advocacy efforts, including an at least annual review of trade association memberships,” noting that “any material or significant issues are reviewed by the Board.” This reflects a formal governance mechanism for indirect lobbying through trade associations with board oversight. However, we found no evidence of a policy or process to align its lobbying with climate-related objectives, no indication of specific climate-focused reviews or audits, and no named individual or committee tasked with overseeing climate lobbying activities.	1