Hilton Worldwide Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Hilton discloses a structured process that links its climate objectives to its public-policy advocacy, but it stops short of publishing a formal lobbying-alignment audit or detailing how it manages misalignment within trade associations. The company states that "one of the three components of the Governance pillar is the commitment to advocate for public policies that advance our Travel with Purpose Goals, which are themselves aligned with the Paris Agreement" and that this framework is embedded into a quarterly reporting cycle whereby "progress toward these commitments are reported quarterly to our Executive Committee, our Board, the Boards NESG committee, and annually in our public reporting." Oversight is clearly assigned: "our Nominating & ESG Committee oversees our ESG strategy," while "the ESG Team and the Government Affairs Team sit within the same function, reporting into an SVP" who provides quarterly updates to the Board, demonstrating named accountability for lobbying alignment. The disclosure also confirms that "our global Government Affairs team engages with legislators, regulators and key government decision makers on ESG-related issues," indicating an internal mechanism to monitor direct lobbying against the companys climate goals. However, while Hilton notes that it is "actively engaged in several industry associations that share common goals" and that it "works closely with these groups to exercise industry leadership, shape public policies and lobby for legislation," we found no evidence of a specific procedure to assess, report on, or correct any climate-policy misalignments within those associations. Likewise, the company does not disclose a standalone public review or third-party audit of its climate-related lobbying. This indicates a moderate level of governance: board-level oversight and a defined process to keep lobbying consistent with climate strategy are in place, but detailed monitoring of indirect lobbying activities and publicly available alignment reviews are not disclosed. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Hilton discloses a structured process that links its climate objectives to its public-policy advocacy, but it stops short of publishing a formal lobbying-alignment audit or detailing how it manages misalignment within trade associations. The company states that "one of the three components of the Governance pillar is the commitment to advocate for public policies that advance our Travel with Purpose Goals, which are themselves aligned with the Paris Agreement" and that this framework is embedded into a quarterly reporting cycle whereby "progress toward these commitments are reported quarterly to our Executive Committee, our Board, the Boards NESG committee, and annually in our public reporting." Oversight is clearly assigned: "our Nominating & ESG Committee oversees our ESG strategy," while "the ESG Team and the Government Affairs Team sit within the same function, reporting into an SVP" who provides quarterly updates to the Board, demonstrating named accountability for lobbying alignment. The disclosure also confirms that "our global Government Affairs team engages with legislators, regulators and key government decision makers on ESG-related issues," indicating an internal mechanism to monitor direct lobbying against the companys climate goals. However, while Hilton notes that it is "actively engaged in several industry associations that share common goals" and that it "works closely with these groups to exercise industry leadership, shape public policies and lobby for legislation," we found no evidence of a specific procedure to assess, report on, or correct any climate-policy misalignments within those associations. Likewise, the company does not disclose a standalone public review or third-party audit of its climate-related lobbying. This indicates a moderate level of governance: board-level oversight and a defined process to keep lobbying consistent with climate strategy are in place, but detailed monitoring of indirect lobbying activities and publicly available alignment reviews are not disclosed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Hilton Worldwide provides a high level of transparency around its climate-related lobbying. It names several specific pieces of legislation and policy processes it has engaged on, including the “Infrastructure Investment and Jobs Act,” the “Inflation Reduction Act,” the “Build Back Better Act,” as well as international frameworks such as the Paris Climate Agreement and EU plans to raise 2030 greenhouse-gas targets under the European Green Deal. The company explains how it conducts this advocacy: it “works with industry associations to influence policymaking,” engages directly with U.S. federal and state policymakers, issues joint statements such as its call for the United States to stay in the Paris Agreement and its letter to “EU leaders,” and leverages its CEO’s chairmanship of the World Travel & Tourism Council and memberships in the American Hotel & Lodging Association and U.S. Travel Association to press positions—demonstrating multiple, clearly identified mechanisms and targets. Hilton also articulates the outcomes it is seeking, backing “tax policy to support energy efficiency upgrades to our hotels,” the “expansion and adaption of EV charging stations,” stronger “greenhouse gas emissions disclosures and reporting,” retention of U.S. participation in the Paris Agreement, and higher EU 2030 emissions-reduction goals. By specifying the policies, the channels it uses to influence them, and the concrete changes it advocates, Hilton offers comprehensive insight into its climate-policy lobbying activities.	A