CSX Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	CSX discloses a detailed and transparent framework for ensuring that both its direct and indirect climate-related lobbying remain aligned with its stated Paris-aligned climate goals, and it has already published the results of that oversight. The company states that it has “outlined our climate position, in line with the Paris Agreement, and policy positions related to climate in our Climate Policy Lobbying Report,” and confirms that “for this report, we evaluated the alignment of the lobbying efforts of our trade associations with the goals of the Paris Agreement.” This public evaluation covers not only trade-association activity but also the company’s own outreach: “we performed an evaluation of CSX’s direct and indirect lobbying efforts, including our participation with select trade associations,” demonstrating that both channels are brought into scope. Clear processes and escalation pathways are described: “if we find that a trade association which we are affiliated with fails to align their policies and activities or fails to commit to an improvement plan, we will consider reducing or discontinuing our contributions and support or withdrawing our membership accordingly,” while direct lobbying is governed through a Political Governance Program that is “designed to facilitate comprehensive evaluation and supervision of pledged funds or resources,” overseen by the “Head of Regulatory and Federal Affairs.” Ultimate oversight is exercised by the Board: “The Governance & Sustainability Committee… reviews and, where required under the PGP, provides approval of… contributions to trade associations for political purposes” and it “has oversight responsibility for environmental matters, including carbon emissions, and has responsibility for climate risk oversight and evaluation, including risks associated with energy and environmental policy.” The company also evidences ongoing monitoring, noting it “will continue to refine the methodology and governance principles used in this evaluation to improve how we manage our industry association memberships in the future,” and that “Government Affairs shall have the sole authority to make decisions regarding Political Contributions… subject to oversight by the Governance and Sustainability Committee.” By combining a publicly available lobbying-alignment report, explicit board-level and executive oversight, a stated review methodology covering both direct and trade-association lobbying, and a willingness to modify or terminate memberships that conflict with its climate stance, CSX demonstrates strong transparency, monitoring and accountability mechanisms for climate lobbying governance. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

CSX discloses a detailed and transparent framework for ensuring that both its direct and indirect climate-related lobbying remain aligned with its stated Paris-aligned climate goals, and it has already published the results of that oversight. The company states that it has “outlined our climate position, in line with the Paris Agreement, and policy positions related to climate in our Climate Policy Lobbying Report,” and confirms that “for this report, we evaluated the alignment of the lobbying efforts of our trade associations with the goals of the Paris Agreement.” This public evaluation covers not only trade-association activity but also the company’s own outreach: “we performed an evaluation of CSX’s direct and indirect lobbying efforts, including our participation with select trade associations,” demonstrating that both channels are brought into scope. Clear processes and escalation pathways are described: “if we find that a trade association which we are affiliated with fails to align their policies and activities or fails to commit to an improvement plan, we will consider reducing or discontinuing our contributions and support or withdrawing our membership accordingly,” while direct lobbying is governed through a Political Governance Program that is “designed to facilitate comprehensive evaluation and supervision of pledged funds or resources,” overseen by the “Head of Regulatory and Federal Affairs.” Ultimate oversight is exercised by the Board: “The Governance & Sustainability Committee… reviews and, where required under the PGP, provides approval of… contributions to trade associations for political purposes” and it “has oversight responsibility for environmental matters, including carbon emissions, and has responsibility for climate risk oversight and evaluation, including risks associated with energy and environmental policy.” The company also evidences ongoing monitoring, noting it “will continue to refine the methodology and governance principles used in this evaluation to improve how we manage our industry association memberships in the future,” and that “Government Affairs shall have the sole authority to make decisions regarding Political Contributions… subject to oversight by the Governance and Sustainability Committee.” By combining a publicly available lobbying-alignment report, explicit board-level and executive oversight, a stated review methodology covering both direct and trade-association lobbying, and a willingness to modify or terminate memberships that conflict with its climate stance, CSX demonstrates strong transparency, monitoring and accountability mechanisms for climate lobbying governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	CSX Corp provides an extensive and concrete picture of its climate-related lobbying. It identifies a range of specific policy instruments it engages on, including the Infrastructure Investment and Jobs Act, the Railroad Crossing Elimination Grant Program, the FRA’s Consolidated Rail Infrastructure and Safety Improvements programme and broader "legislation to limit emissions of carbon dioxide and other greenhouse gases," as well as policy areas such as minimum energy-efficiency requirements and low-carbon R&D. The company also explains how it lobbies and at whom those efforts are directed: it describes "direct engagement with policymakers at the local, state, and federal levels," monthly meetings between its CEO and Members of Congress and the Administration, participation in Railroad Day on Capitol Hill, and collaboration with federal, state and local governments through projects such as the National Gateway; together with a "strong brand campaign designed to increase public awareness of the environmental benefits of rail," these examples demonstrate multiple mechanisms and clearly named targets such as the FRA, individual Senators and federal agencies. Finally, CSX spells out the concrete outcomes it seeks—advocating to "expand the national freight network" so more freight shifts to lower-carbon rail, supporting inter-modal efficiency improvements that it says will "decreas[e] fuel consumption by nearly 2 billion gallons and reduc[e] carbon dioxide emissions by 20 million tons in the project's first 30 years of operation," and urging climate legislation that encourages rail use and the development of carbon-capture technologies. By detailing the policies addressed, the methods and audiences for its advocacy, and the specific environmental and legislative changes it aims to secure, the company demonstrates a high level of transparency in its climate-policy lobbying.	A