United Airlines Holdings Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive United Airlines Holdings Inc. 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 "Inflation Reduction Act of 2022," where it advocated for Sustainable Aviation Fuel (SAF) production tax credits, and state-level initiatives like the "Illinois SAF Tax Credits" and Colorado's clean fuel incentives. It also highlights its involvement in international frameworks like the "Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)," providing clear and identifiable details about its policy engagements. United Airlines provides detailed information about its lobbying mechanisms, including direct engagement with federal policymakers, collaboration with the Biden Administration on the SAF Grand Challenge, and participation in industry-wide groups such as Airlines for America (A4A) and the International Air Transport Association (IATA). The company also identifies specific targets, such as the FAA, U.S. delegates, and state-level policymakers in Illinois, Colorado, and California. Furthermore, United Airlines has been explicit about the policy outcomes it seeks, such as creating economic incentives for increased SAF production, advocating for tax incentives for lower-carbon fuels and carbon removal technologies, and supporting the Biden Administration's SAF Grand Challenge to supply 3 billion gallons of SAF domestically by 2030. These disclosures clearly articulate the desired policy changes and measurable goals United is pursuing, demonstrating a high level of transparency in its climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Comprehensive United Airlines demonstrates a comprehensive climate lobbying governance process, as evidenced by its publication of a "Climate Lobbying Report: Aligning Climate Leadership with Advocacy," which provides transparency into its lobbying activities and alignment with climate goals. The company also has a "Lobbying and Political Activity Policy statement" that outlines its participation in the political process and policy advocacy, further emphasizing its commitment to climate-related lobbying alignment. Governance oversight is provided by United's Disclosure Council, which meets quarterly to review disclosures and discuss changes that may be appropriate, and includes subject matter experts to ensure compliance with disclosure requirements and alignment with climate goals. Additionally, United Airlines has mapped its ESG disclosures across metrics outlined in the Task Force on Climate-Related Financial Disclosures (TCFD) framework, indicating robust monitoring and accountability mechanisms. The governance structure includes key individuals such as the CEO, Chief Legal Officer, and Vice President and Controller, who are actively involved in overseeing climate-related disclosures and lobbying alignment. This indicates a thorough governance process that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms and accountability structures in place. 4