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| Overall Assessment |
Comment |
Score |
| Comprehensive |
ExxonMobil has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company explicitly names specific climate policies and legislation it has engaged with, such as the U.S. Inflation Reduction Act (IRA), the Global Methane Pledge, and the U.S. Methane Emissions Reduction Action Plan. It also references its advocacy for durable methane regulations, carbon pricing, and carbon capture and storage (CCS) frameworks, including detailed provisions like the expansion of the IRA's 45V tax credit and streamlined permitting processes. ExxonMobil provides detailed information about its lobbying mechanisms, including direct engagement through comment letters to the U.S. Environmental Protection Agency (EPA), participation in trade associations, and collaborations with multi-stakeholder initiatives like the Methane Guiding Principles. The company identifies specific policymaking targets, such as the U.S. House of Representatives, U.S. Senate, Department of Energy, and the European Union, ensuring clarity on its lobbying efforts. Furthermore, ExxonMobil clearly articulates the policy outcomes it seeks, such as comprehensive rules to reduce methane emissions, the establishment of a carbon intensity-based fuel standard, and the development of regulatory frameworks for CCS and hydrogen technologies. These disclosures reflect a high degree of transparency in the company's climate lobbying activities.
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4
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
ExxonMobil demonstrates a comprehensive governance process for climate lobbying alignment, as evidenced by its detailed disclosures and alignment efforts. The company has published an annual lobbying report, which it expects to update annually, providing "additional detail of our direct and indirect climate-related lobbying activities at the federal, state and local level, as well as our grassroots lobbying communications." This report includes lobbying expenses from over 100 organizations and outlines the issues lobbied, ensuring transparency in its lobbying activities. ExxonMobil explicitly mentions aligning its indirect lobbying efforts, stating that it "regularly reviews our memberships for alignment on climate-related policy issues and other topics" and has a process to address misalignment, including withdrawing support from organizations that fail to engage constructively, as demonstrated by its withdrawal from the American Legislative Exchange Council (ALEC) in 2018.
The governance process is robust, with clear oversight structures. The Vice President for Public and Government Affairs, who reports directly to the CEO, is "responsible for the stewardship of identified key public policy issues, which guide the company's lobbying efforts and political contributions." Additionally, lobbying and political engagement are "included as part of the Board's stewardship of the company's enterprise-risk framework," with annual presentations to the Board and its Public Issues and Contributions Committee (PICC), which is composed entirely of independent directors. The directors review lobbying efforts and expenditures, ensuring accountability.
ExxonMobil has also conducted a global review of trade association memberships, assessing their alignment with climate-related policy principles. The company has identified 51 organizations active in climate policy discussions and categorized them as aligned, partially aligned, or misaligned. For misaligned organizations, ExxonMobil has outlined specific areas of misalignment and engaged constructively to enhance alignment, with plans to "monitor internal developments and external statements to assess commitment to constructive engagement" and "annually review and publicly report alignment classifications." This indicates a thorough monitoring and management process for both direct and indirect lobbying activities.
Overall, ExxonMobil's governance framework includes detailed disclosures, alignment processes, oversight by senior executives and the Board, and proactive engagement with trade associations, reflecting strong accountability and transparency in its climate lobbying governance.
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4
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