Pembina Pipeline Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Pembina Pipeline Corporation is highly transparent about its climate-related lobbying. It names a wide range of specific policies it seeks to influence, including Alberta’s Technology Innovation and Emissions Reduction (TIER) Regulation, the federal Clean Fuel Standard, Alberta’s Methane Emission Reduction Regulation, federal guidance to “cap and cut oil and gas sector GHG emissions,” directives 060 and 017 on flaring and measurement, the Hydrogen Strategy for Canada, and tax and regulatory measures supporting CCUS. The company also explains in detail how it lobbies and whom it targets: it submitted “written comments” to the Alberta government during the TIER consultation, maintains “regular written and verbal contact with federal and provincial policymakers and regulators” on methane rules, participates in the Government of Alberta’s CCUS Industry Advisory Group, and “collaborat[es] with Finance Canada on the design of a CCUS tax measure,” as well as working through trade associations such as the Canadian Energy Pipeline Association. Finally, Pembina spells out the concrete outcomes it is pursuing, such as retaining the existing lifetime of carbon credits under TIER, advocating for “a performance-based policy approach that ensures reduction of methane emissions from the midstream sector is cost effective, promotes innovation, and does not undermine competitiveness,” supporting “tailored industrial energy efficiency funding programs,” and promoting policies that accelerate CCUS deployment and wider hydrogen adoption. These detailed disclosures about the policies, the engagement channels, the governmental targets, and the specific changes sought demonstrate a comprehensive level of transparency around the company’s climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Pembina Pipeline Corp has established some governance for its climate-related policy engagement by assigning oversight to senior executives and embedding an annual planning cycle. It discloses that “Pembina’s public policy engagement work and government advocacy is overseen by the Senior Vice President External Affairs, Chief Legal Counsel and Chief Sustainability Officer,” and that “Pembina's External Affairs unit is responsible for ensuring that all engagement with government and public sector stakeholders on matters of legislative, regulatory, or policy development related to climate change is conducted in a manner that is aligned to our business's overarching climate change strategy.” The company further states that “we develop robust engagement plans on an annual basis with all priority stakeholder groups and identify issues upon which we can engage to advance of our climate change strategy,” which indicates a structured process for aligning direct lobbying activities. However, the company does not disclose any process for vetting or managing indirect lobbying through trade or industry associations, no formal board or committee review of lobbying alignment, and no independent audit of these efforts. We found no evidence of a commitment to align engagement with the goals of the Paris Agreement, as noted in the response that “No, and we do not plan to have one in the next two years.” These gaps imply that, while Pembina has defined roles and an annual planning mechanism for climate engagement, its overall governance lacks comprehensive oversight, monitoring procedures, and alignment across all lobbying channels.	2