Gibson Energy Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Gibson Energy Inc has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names several specific climate policies it has engaged with, including the "Canadian Net-Zero Emissions Accountability Act," "Canada's Clean Fuels Fund," the "Output-Based Pricing System," the "Greenhouse Gas Pollution Pricing Act," and the "Forward Regulatory Plan 2022 to 2024, Environment and Climate Change Canada." These disclosures provide detailed information about the focus and geographic scope of each policy, such as carbon pricing, emissions regulations, and alternative fuels, and clearly identify the policies being lobbied. Gibson Energy also provides detailed information about its lobbying mechanisms and targets, mentioning direct engagement with "Environment and Climate Change Canada (ECCC)" and ongoing discussions with the provincial government regarding GHG and air emissions regulations for the midstream sector. The company specifies mechanisms such as discussions and applications, and identifies targets like policymakers and government entities, ensuring clarity about how and with whom it engages. Furthermore, Gibson Energy has been transparent about the specific outcomes it seeks through its lobbying efforts, such as aligning its internal carbon pricing with the government's legislation to set a carbon price of $170 per tonne by 2030, securing funds from the Clean Fuels Fund for its renewable diesel facility, and ensuring that public policy balances environmental benefits with competitiveness across geographical boundaries. These disclosures illustrate Gibson Energy's comprehensive approach to climate lobbying transparency and alignment with broader climate objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Gibson's disclosures provide evidence of a structured process for aligning its lobbying activities with its broader climate strategy, underpinned by clear internal oversight and monitoring mechanisms. The company details that "the risks associated with climate policy are monitored by several groups and are escalated to Gibson's management team through our ERM process as required," and it identifies key personnel – notably "our Sustainability Supervisor and Director of Supply Chain Management, ESG and Stakeholder Relations" – who are tasked with ensuring consistency in climate-related engagements. Furthermore, Gibson leverages internal expertise and engages a third-party government relations team to stay abreast of regulatory changes, reflecting efforts to manage both direct and indirect lobbying activities. Although some disclosures suggest that the company conducts only minimal lobbying or omit explicit public commitments regarding alignment with the Paris Agreement, the internally comprehensive approach described underscores a robust governance process focused on maintaining alignment with its climate commitments.	3