Hilton Worldwide Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Hilton Worldwide Holdings Inc has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly disclosed its engagement with specific climate policies, such as the "Infrastructure Investment and Jobs Act" and the "Inflation Reduction Act," and has detailed its advocacy efforts, including support for legislation related to "tax policy to support energy efficiency upgrades to our hotels," "expansion and adaption of EV charging stations," and "greenhouse gas emissions disclosures and reporting." Hilton has also joined collective statements with other businesses to influence U.S. and EU climate policies, such as urging the U.S. to remain in the Paris Agreement and calling on EU leaders to raise GHG emissions targets. Regarding lobbying mechanisms, Hilton engages directly with policymakers and works through industry associations like the World Travel and Tourism Council (WTTC) and the American Hotel and Lodging Association (AHLA). However, while Hilton identifies broad targets and mentions participation in industry groups, it does not consistently specify the exact mechanisms of engagement, such as meetings or letters, nor does it always identify specific government entities targeted. Hilton has been transparent about the specific outcomes it seeks through its lobbying efforts, such as advancing legislation that "helps our hotels become more sustainable, including tax incentives for energy efficiency upgrades, EV charging stations and plastic elimination." Additionally, Hilton has supported ambitious climate goals, including advocating for the U.S. to remain committed to the Paris Climate Agreement and calling on EU leaders to raise EU 2030 GHG emissions targets and endorse the European Green Deal. These disclosures align with Hilton's broader climate transition plan and 2030 goals, demonstrating a high level of transparency in its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Hilton demonstrates a structured approach to ensuring that its climate lobbying efforts align with its overarching climate strategy. The company's disclosure that it has "created our ESG Strategic Framework" to "advocate for public policies that advance our Travel with Purpose Goals, which are themselves aligned with the Paris Agreement" is complemented by clear monitoring and accountability, as evidenced by the statement that "progress toward these commitments are reported quarterly to our Executive Committee, our Board, the Board's NESG committee, and annually in our public reporting." Additionally, the assignment of responsibility is clearly defined with the ESG Team and the Government Affairs Team operating within the same function, reporting into an SVP who in turn provides oversight to the Board and its NESG Committee. Although some accounts do not explicitly detail mechanisms for climate lobbying governance, the explicit description of internal oversight, regular monitoring, and defined accountability in this disclosure indicates strong governance practices for climate lobbying alignment.	3