Southern Co/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Southern Company discloses a detailed and recurring governance system that covers both its own advocacy and its participation in trade associations and is expressly tied to its net-zero strategy. The company states that "Members of the Southern Company Management Council meet at least quarterly to review the public statements, positions, and missions of the associations to assess, among other things, whether the association is aligned with our net zero goal," demonstrating an ongoing mechanism to screen and, if needed, disengage from mis-aligned bodies: "when a group is significantly misaligned we evaluate and determine whether to continue our membership." Oversight is clearly assigned: "Both the Board of Directors and management play important roles in overseeing our political engagement activities. The Nominating, Governance and Corporate Responsibility Committee has primary oversight and Southern Companys lobbying-related activities are reviewed at least annually by the full Board," with additional "periodic review by our internal auditing organization" that reports to the Audit Committee. For transparency the company has produced an explicit lobbying-alignment report"We published a Trade Association and Climate Engagement Report along with an assessment of whether the climate change statements or positions of key trade associations are aligned with the goals of the Paris Agreement"which goes beyond financial disclosure to analyse consistency with its climate objectives. Decision-making processes extend to direct lobbying, as the firm has "put in place decision-making and oversight processes for political expenditures and all governmental relations activities," indicating that its own advocacy is also checked against climate strategy. Collectively, the board-level mandate, the named committee and management council, the quarterly review cycle, and the published alignment assessment indicate comprehensive governance of both direct and indirect climate-related lobbying. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Southern Company discloses a detailed and recurring governance system that covers both its own advocacy and its participation in trade associations and is expressly tied to its net-zero strategy. The company states that "Members of the Southern Company Management Council meet at least quarterly to review the public statements, positions, and missions of the associations to assess, among other things, whether the association is aligned with our net zero goal," demonstrating an ongoing mechanism to screen and, if needed, disengage from mis-aligned bodies: "when a group is significantly misaligned we evaluate and determine whether to continue our membership." Oversight is clearly assigned: "Both the Board of Directors and management play important roles in overseeing our political engagement activities. The Nominating, Governance and Corporate Responsibility Committee has primary oversight and Southern Companys lobbying-related activities are reviewed at least annually by the full Board," with additional "periodic review by our internal auditing organization" that reports to the Audit Committee. For transparency the company has produced an explicit lobbying-alignment report"We published a Trade Association and Climate Engagement Report along with an assessment of whether the climate change statements or positions of key trade associations are aligned with the goals of the Paris Agreement"which goes beyond financial disclosure to analyse consistency with its climate objectives. Decision-making processes extend to direct lobbying, as the firm has "put in place decision-making and oversight processes for political expenditures and all governmental relations activities," indicating that its own advocacy is also checked against climate strategy. Collectively, the board-level mandate, the named committee and management council, the quarterly review cycle, and the published alignment assessment indicate comprehensive governance of both direct and indirect climate-related lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Southern Company provides a highly detailed and candid picture of its climate-policy lobbying. It names multiple identifiable measures it has worked on, including a “well-designed carbon tax,” a “clean energy/electricity standard (CES),” performance-based “methane regulations,” and specific provisions in the Inflation Reduction Act such as the “Extension of investment tax credits (ITCs) and production tax credits (PTCs) for wind and solar projects,” “Energy storage ITCs,” and the expansion of “Section 45Q” carbon-capture incentives. The company also discloses how it lobbies and whom it targets, describing “direct, open communication with various policymakers, regulators and stakeholders,” a permanent “presence in Washington, D.C., that enables constructive dialogue with policymakers and the federal government,” engagement “with the Administration, Senate and House Leadership, Senate Finance Committee and House Ways and Means Committee,” and work through trade groups like the Edison Electric Institute and the American Clean Power Association. Finally, it is explicit about the concrete outcomes it seeks: it wants an economy-wide pathway to net-zero emissions, extension of clean-energy tax credits, “a well-designed CES for the electric sector,” incentives for low- and zero-emitting vehicles, and methane rules aligned with ONE Future’s 2025 goal, all aimed at delivering an “affordable, reliable transition to net zero for our customers.” This breadth of named policies, clear description of lobbying channels and targets, and precise articulation of desired legislative and regulatory changes demonstrates a comprehensive level of transparency around the company’s climate-related lobbying activities.	A