Chevron Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Chevron Corp has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has explicitly named specific climate-related policies and legislation it has engaged with, such as the "2023-2028 National Outer Continental Shelf Oil and Gas Leasing Proposed Program," California Senate Bill (SB) X1-2, and the "Federal Acquisition Regulation: Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk." Chevron also disclosed its support for the creation of a Climate Committee at the American Petroleum Institute (API) and its advocacy for the reauthorization of Advanced Research Projects Agency–Energy (ARPA-E) and the expansion of the Regional Greenhouse Gas Initiative (RGGI). These examples reflect Chevron's transparency in naming the policies it has lobbied for. Chevron has also provided detailed information about its lobbying mechanisms and targets. The company disclosed its engagement in direct lobbying through employees and contract lobbyists, as well as indirect lobbying via trade associations. Specific examples include submitting comments to the Bureau of Ocean Energy Management (BOEM) and the Environmental Protection Agency (EPA), addressing named officials such as Administrator Michael S. Regan, and participating in trade associations like the American Petroleum Institute (API) and the Business Roundtable (BRT). Chevron also highlighted its use of advanced methane detection technologies and collaborations with third-party monitoring programs, showcasing both direct and indirect lobbying mechanisms. Furthermore, Chevron has been explicit about the outcomes it seeks through its lobbying efforts. The company advocates for economywide carbon pricing as the primary policy tool to address climate change, supports performance-based methane regulations, and emphasizes the importance of technological innovation, such as advanced methane detection technologies. Chevron has also articulated its opposition to policies like SB X1-2, arguing that it would reduce investment and hurt consumers, while advocating for alternative solutions that incentivize innovation and investment. These disclosures clearly outline Chevron's desired policy changes and legislative goals, demonstrating a high level of transparency in its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Chevron demonstrates a comprehensive climate lobbying governance process, as evidenced by its detailed disclosures and oversight mechanisms. The company has published a "Climate Lobbying Report" in response to stockholder interest and at the Board's direction, which provides transparency into its lobbying activities and alignment with climate goals. Chevron explicitly mentions aligning its indirect lobbying efforts, including activities conducted through trade associations, stating, "Chevron works with trade associations to advocate for effective, responsible and nonpartisan standards, regulations and energy policies." Furthermore, Chevron has established policies and processes to ensure alignment, such as the annual review of trade association memberships by senior staff and the Board of Directors Public Policy and Sustainability Committee, which "annually reviews Chevron's lobbying activities and budget, including trade association memberships, to assess value and alignment with Chevron's interests." The governance structure includes clear accountability, with the vice president of Corporate Affairs responsible for providing an effective political engagement program, and the Public Policy and Sustainability Committee overseeing political activities and ensuring alignment with Chevron's positions and interests. Chevron also employs a "robust training and audit program" and conducts regular reviews of its lobbying and related processes to ensure compliance with laws and internal policies. Additionally, Chevron provides extensive disclosure, including a five-year history of trade association memberships and lobbying expenditures, as well as links to lobbying reports across various jurisdictions. This indicates a thorough governance process with monitoring mechanisms, responsible parties, and transparency measures in place.	4