Halliburton Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Halliburton provides a moderate level of transparency around its climate-related lobbying. It identifies the broad policy theme it engages on—hydraulic fracturing and the role of natural gas in the energy transition—but does not cite any specific bills or regulatory proposals. The company is clearer about how it engages, noting it "meet[s] with public officials and policy makers on matters that are of importance to our business," participates in "technical roundtable meetings," publishes "technical peer-reviewed publications," and contributes information to websites such as FracFocus; it also names concrete targets for these activities, including the U.S. Environmental Protection Agency and individual U.S. state agencies. On the purpose of its advocacy, Halliburton offers only a general position that "clean natural gas is a sound alternative to other sources of energy" and that hydraulic fracturing will make this resource more available, without detailing the specific regulatory changes or legislative outcomes it is seeking. Together, these disclosures give a clear picture of the methods and interlocutors involved, but leave important gaps regarding the precise policies influenced and the concrete results the company hopes to achieve.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Halliburton maintains formal oversight over its political engagement but provides limited detail on climate-lobbying alignment and management processes. It notes that “The Nominating and Corporate Governance Committee is responsible for oversight of political expenditures, payments to trade associations, and lobbying activity,” and it issues “Updates from management, on an annual basis, regarding any political contributions made by the Company… including any expenditures on lobbyists and political action committees, and any contributions to U.S. trade organizations.” The company has published its “Halliburton Policies for Political Engagement” report on its website and affirms it has a “public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement.” Nonetheless, we found no evidence of a formal process for reviewing or managing the alignment of direct or indirect climate-related lobbying, such as board sign-off on specific climate-lobbying plans, trade-association alignment reviews, or criteria for assessing associations whose positions may conflict with its climate commitments.	2