Sempra – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Sempra discloses a well-structured governance system that explicitly covers both its own policy advocacy and its membership in trade associations, anchored by board-level oversight and a defined review process. The company states that "Sempra’s governance structure includes policies and practices for political engagement, necessitating the active involvement and oversight of our board of directors, specifically the Corporate Governance Committee of the board," and that "The Corporate Governance Committee reviews Sempra’s public policy priorities on an annual basis, including political contributions and lobbying activities, while Sempra’s senior vice president of corporate affairs is responsible for the activities, positions and daily decision-making consistent with this oversight." Operationally, a "lobbying activity tracking system helps us manage political activity and meet local, state and federal political reporting requirements," and in 2023 the firm "implemented a political reporting and compliance plan…strengthening policies, and enhancing tracking and reporting systems," indicating an ongoing monitoring mechanism. For indirect lobbying, Sempra has created a "standardized trade association template" sent to associations with dues over $20,000 and "evaluated the trade associations’ responses to assess their climate-related policy and advocacy positions," reporting "Alignment with 29 associations; Partial alignment with eight associations; and Misalignment with zero associations." Where differences arise, the company outlines three mitigation steps: "1. Education of the association staff and key members. 2. Ongoing engagement with the association to try to move consensus positions. 3. If needed, dissension from association positions, including not providing formal company participation or endorsement," demonstrating an active alignment process. These disclosures show clear oversight, defined procedures and coverage of both direct and indirect lobbying, which indicates strong governance; however, the company does not disclose an external or detailed public audit of its climate-lobbying alignment, nor does it provide criteria for determining "partial alignment" or examples of withdrawing from misaligned associations, so the transparency of outcomes and third-party assurance appear limited. View Sources	B

Overall Assessment

Analysis

Score

Strong

Sempra discloses a well-structured governance system that explicitly covers both its own policy advocacy and its membership in trade associations, anchored by board-level oversight and a defined review process. The company states that "Sempra’s governance structure includes policies and practices for political engagement, necessitating the active involvement and oversight of our board of directors, specifically the Corporate Governance Committee of the board," and that "The Corporate Governance Committee reviews Sempra’s public policy priorities on an annual basis, including political contributions and lobbying activities, while Sempra’s senior vice president of corporate affairs is responsible for the activities, positions and daily decision-making consistent with this oversight." Operationally, a "lobbying activity tracking system helps us manage political activity and meet local, state and federal political reporting requirements," and in 2023 the firm "implemented a political reporting and compliance plan…strengthening policies, and enhancing tracking and reporting systems," indicating an ongoing monitoring mechanism. For indirect lobbying, Sempra has created a "standardized trade association template" sent to associations with dues over $20,000 and "evaluated the trade associations’ responses to assess their climate-related policy and advocacy positions," reporting "Alignment with 29 associations; Partial alignment with eight associations; and Misalignment with zero associations." Where differences arise, the company outlines three mitigation steps: "1. Education of the association staff and key members. 2. Ongoing engagement with the association to try to move consensus positions. 3. If needed, dissension from association positions, including not providing formal company participation or endorsement," demonstrating an active alignment process. These disclosures show clear oversight, defined procedures and coverage of both direct and indirect lobbying, which indicates strong governance; however, the company does not disclose an external or detailed public audit of its climate-lobbying alignment, nor does it provide criteria for determining "partial alignment" or examples of withdrawing from misaligned associations, so the transparency of outcomes and third-party assurance appear limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Sempra provides an exceptionally detailed picture of its climate-policy advocacy. Across its disclosures it names well over a dozen identifiable pieces of legislation and regulatory frameworks it has worked on, including federal measures such as the Inflation Reduction Act, the expanded 45Q tax credit and H.R. 2801 (the METHANE Act), and a wide range of California bills (e.g., SB 1020, SB 1158, SB 1075 on green hydrogen, SB 905 on carbon capture, AB 2316 on community renewable energy, and AB 3074 on wildfire resilience). The company also references its engagement with broader initiatives like California’s 2045 carbon-neutrality goal, the U.S. EPA methane rules and the Paris Agreement, making it clear which policies it seeks to influence. It is equally explicit about how and where it lobbies: disclosures state that “Sempra’s Sacramento advocates worked with legislative staff via meetings, email, telephone calls, and/or position statements,” that it holds briefings for Capitol Hill stakeholders, files applications with regulators such as CPUC and FERC, and pursues indirect lobbying through trade associations, adding that “regular participation with these organizations helps provide us an opportunity to influence their positions.” Specific targets are named, including federal legislators, California legislative staff and state regulators. Finally, the company spells out the concrete outcomes it seeks, such as expanding 45Q incentives to cover LNG facilities, maintaining and enlarging tax credits for wind, solar, EVs and hydrogen infrastructure, securing regulatory approval for hydrogen blending and the Angeles Link hub, reducing wildfire risk through vegetation-management legislation, and promoting in-state production and use of biomethane in support of the state’s 2045 neutrality goal. This combination of clearly identified policies, well-described mechanisms and explicit desired outcomes demonstrates a comprehensive level of transparency around Sempra’s climate-related lobbying activities.	A