MGM Resorts International – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	MGM Resorts International discloses a limited but identifiable process to keep its policy engagement in line with its climate strategy, stating 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 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." Governance responsibility is explicitly assigned to the Board-level Corporate Social Responsibility & Sustainability Committee, which "meets multiple times per year with management to review significant policies and performance and provides guidance on ESG topics," and the company confirms that this committee would intervene on misaligned engagement. This indicates the existence of a policy-based review mechanism and a named oversight body, suggesting some governance strength. However, the disclosures do not set out how lobbying activities—either the company’s direct advocacy or its participation in trade associations—are systematically monitored, audited, or aligned over time, nor do they describe any instances of engaging, correcting, or exiting third-party groups whose positions conflict with the company’s climate goals. There is also no published lobbying alignment report, no description of internal controls such as pre-approval of specific lobbying positions, and no reference to dedicated management of political spending. Consequently, while MGM Resorts shows that its Board committee can halt inconsistent engagement, the company does not disclose a detailed, ongoing governance framework that covers both direct and indirect lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

MGM Resorts International discloses a limited but identifiable process to keep its policy engagement in line with its climate strategy, stating 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 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." Governance responsibility is explicitly assigned to the Board-level Corporate Social Responsibility & Sustainability Committee, which "meets multiple times per year with management to review significant policies and performance and provides guidance on ESG topics," and the company confirms that this committee would intervene on misaligned engagement. This indicates the existence of a policy-based review mechanism and a named oversight body, suggesting some governance strength. However, the disclosures do not set out how lobbying activities—either the company’s direct advocacy or its participation in trade associations—are systematically monitored, audited, or aligned over time, nor do they describe any instances of engaging, correcting, or exiting third-party groups whose positions conflict with the company’s climate goals. There is also no published lobbying alignment report, no description of internal controls such as pre-approval of specific lobbying positions, and no reference to dedicated management of political spending. Consequently, while MGM Resorts shows that its Board committee can halt inconsistent engagement, the company does not disclose a detailed, ongoing governance framework that covers both direct and indirect lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	MGM Resorts International provides a comprehensive picture of its climate-related lobbying. It explicitly names the key measures it has worked on, including Nevada SB 358 to raise the state’s Renewable Portfolio Standard to 50 % by 2030, Nevada SB 448—an omnibus bill to expand transmission, electrify transport and increase carbon-free generation—and the Southern Nevada Water Authority’s 2022 Water Conservation Goal and associated regulations. The company also details how it lobbied: members of its Government Affairs, Social Impact & Sustainability and Facilities COE teams “directly engaged with members of the Nevada Legislature and interested parties to refine and craft the details” of SB 448; it “engaged with the U.S. Department of Energy” on lighting-efficiency standards; and it advanced water-conservation rules through the Nevada Resort Association while supporting rate-setting at the Southern Nevada Water Authority. Target entities are clearly identified, ranging from the Nevada Legislature and the SNWA to the U.S. Congress and the DOE. Finally, MGM spells out the policy outcomes it is pursuing: codifying a 50 % renewable-energy standard by 2030, enabling major investments in transmission lines and electric-vehicle infrastructure, encouraging utility and end-user energy-efficiency measures and new lighting standards, and cutting regional water demand to 86 gallons per capita per day by 2035 while funding the SNWA’s $3.5 billion resource plan. This level of specificity on policies, mechanisms and desired results demonstrates a high degree of transparency in the company’s climate-policy lobbying.	A