US Foods Holding Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	US Foods provides a straightforward statement that it does not participate in climate-related lobbying, noting “To our knowledge, we have not been actively involved with any organization’s efforts to influence policy, law or regulation that may impact the climate.” This single declaration makes clear that (a) the company has not sought to shape any climate policy, (b) it has employed no direct or indirect lobbying channels, and (c) it therefore pursues no policy outcomes. The disclosure offers reasonable transparency by explicitly confirming non-engagement, yet it stops short of explaining why the company chooses not to lobby or outlining the specific policy areas it might otherwise have engaged on. As a result, while readers are told unambiguously that no climate lobbying takes place, the absence of contextual detail limits the depth of insight available.	2

Lobbying Governance

Overall Assessment	Comment	Score
None	US Foods Holding Corp does not disclose any governance processes for aligning its lobbying or engagement with climate goals, as it states “No, and we do not plan to have one in the next two years” when asked about a public commitment to the goals of the Paris Agreement. We found no evidence of any policy, oversight mechanism, defined review process, or designated individual or committee responsible for ensuring that its direct or indirect lobbying activities support its climate objectives. The company does not disclose any monitoring or management procedures, which indicates a lack of transparency and internal governance framework for climate-related lobbying.	0