MGM Resorts International

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	MGM Resorts International has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly disclosed its engagement with specific climate-related policies, such as Nevada SB 448, which aims to expand energy transmission infrastructure, enhance transportation electrification, and support carbon-free electricity generation. Additionally, it supports the Southern Nevada Water Authority's water conservation goal, revised in 2021, to address regional water resource challenges. These disclosures provide detailed information about the policies engaged and their relevance to climate action. MGM Resorts International has also been transparent about its lobbying mechanisms, including direct engagement with members of the Nevada Legislature and other stakeholders to refine and craft the details of Nevada SB 448, as well as supporting water rate increases through its membership in the Nevada Resort Association to fund the Southern Nevada Water Authority's conservation initiatives. The company identifies specific targets of its lobbying efforts, such as the Nevada Legislature, the U.S. Department of Energy, and the Southern Nevada Water Authority, and describes its mechanisms, including participation in trade associations and direct interactions with policymakers. Furthermore, MGM Resorts International has been clear about the specific outcomes it seeks through its lobbying efforts, such as facilitating significant investments in electricity transmission and electric vehicle infrastructure through Nevada SB 448 and supporting the Southern Nevada Water Authority's water conservation goal of reducing per capita water usage to 86 gallons per day by 2035. These desired outcomes align with broader climate resilience and sustainability objectives, demonstrating a high level of transparency in its lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	MGM Resorts International states that "our environmental policy establishes priorities for the company and serves as the foundation for ensuring that all engagement is consistent through the review and consultation process," and further explains that "if any engagement is determined inconsistent, this would be identified by the CSR Committee of the Board and other key stakeholders, and then all engagement activities would cease or be addressed as appropriate." Although some evidence claims there is limited mention of how the company ensures alignment between its lobbying activities and climate goals, these disclosures highlight a defined framework and responsible parties for governance, indicating that MGM Resorts International has a formal policy-based review process to manage climate lobbying alignment, supported by oversight from the CSR Committee.	3