Hydro One Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Hydro One provides some insight into how its public-policy activities are governed, but the disclosures remain partial and largely descriptive. The company states that "The Governance & Regulatory Committee oversees Hydro One’s regulatory, customer and public policy matters" and that the committee’s mandate was expanded "to recognize the importance of regulatory and public policy matters within the electricity sector," signalling that a formal Board committee is responsible for supervising lobbying and advocacy work. Day-to-day management is assigned to a named management body: "The Chief Regulatory Officer and Vice President Stakeholder Relations co-chair the leadership level Strategic Policy Committee, which is responsible for developing the company’s strategic regulatory and policy positions and initiatives," demonstrating at least one concrete mechanism for setting and vetting lobbying positions. Hydro One also discloses that it "regularly monitor[s] climate change policy developments and assess[es] their potential impact on our business" and that it "engage[s] in proactive policy development to support greater electrification in Ontario," indicating that climate considerations are included when policy stances are formed. Finally, the company provides examples of direct climate-related advocacy—such as meeting with the "Electrification and Energy Transition Panel" and giving the Ontario Energy Board feedback to "enable energy transition-related investments"—which suggests efforts to align its lobbying with its climate-oriented business strategy. However, the company does not disclose any systematic review of the alignment between its lobbying and its climate goals, offers no information on how it assesses or manages the positions of trade associations, and publishes no dedicated climate-lobbying audit or alignment report. The absence of publicly described escalation, corrective, or withdrawal procedures for misaligned advocacy indicates that the governance framework is only moderately developed. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Hydro One provides some insight into how its public-policy activities are governed, but the disclosures remain partial and largely descriptive. The company states that "The Governance & Regulatory Committee oversees Hydro One’s regulatory, customer and public policy matters" and that the committee’s mandate was expanded "to recognize the importance of regulatory and public policy matters within the electricity sector," signalling that a formal Board committee is responsible for supervising lobbying and advocacy work. Day-to-day management is assigned to a named management body: "The Chief Regulatory Officer and Vice President Stakeholder Relations co-chair the leadership level Strategic Policy Committee, which is responsible for developing the company’s strategic regulatory and policy positions and initiatives," demonstrating at least one concrete mechanism for setting and vetting lobbying positions. Hydro One also discloses that it "regularly monitor[s] climate change policy developments and assess[es] their potential impact on our business" and that it "engage[s] in proactive policy development to support greater electrification in Ontario," indicating that climate considerations are included when policy stances are formed. Finally, the company provides examples of direct climate-related advocacy—such as meeting with the "Electrification and Energy Transition Panel" and giving the Ontario Energy Board feedback to "enable energy transition-related investments"—which suggests efforts to align its lobbying with its climate-oriented business strategy. However, the company does not disclose any systematic review of the alignment between its lobbying and its climate goals, offers no information on how it assesses or manages the positions of trade associations, and publishes no dedicated climate-lobbying audit or alignment report. The absence of publicly described escalation, corrective, or withdrawal procedures for misaligned advocacy indicates that the governance framework is only moderately developed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Hydro One provides a comprehensive and transparent account of its climate-related lobbying activities. It names the specific policies and regulatory processes in which it participates, including the 'Electrification and Energy Transition Panel' convened by the Province of Ontario, formal feedback on the 'Pathways to Decarbonization Report' requested by the Ministry of Energy, and participation in 'OEB Regulatory Framework Workshops' to guide energy transition investments. Its disclosures spell out the mechanisms used—direct engagements such as meetings with the panel, feedback submissions to the Ministry and interactive workshops organized by the Ontario Energy Board—and clearly identify targets of its efforts, from the Ministry of Energy to the OEB. Moreover, Hydro One explicitly states the outcomes it seeks: enabling proactive electricity system investments to support both the energy transition and sustainable economic development, endorsing the short-, medium- and long-term infrastructure recommendations within the report’s 'no-regret' framework, and advocating for regulatory reforms that facilitate energy transition investments while protecting customer interests. This level of specificity across what was lobbied, how it was lobbied, and the policy changes sought demonstrates comprehensive transparency in its climate lobbying disclosures.	A