Keyera Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Keyera has implemented a multi-channel governance process to align its policy influencing activities with its climate change strategy. It reports that “Our External Affairs Team … reports directly to Senior Vice President, Sustainability, External Affairs & General Counsel who has oversight of and ensures corporate alignment of Keyera’s policy engagements, industry involvement and external relations activities,” and indicates that this role also oversees “Keyera’s membership in industry associations.” The company explains that “The General Manager, External Relations, had oversight of Keyera’s semi-annual reporting to the Alberta Lobbyists Act,” providing a recurring monitoring mechanism for lobbying activities. Keyera further describes that “Keyera’s Executive team is consulted on climate-related issues and potential adjustments advocacy” and that “these types of disclosures are reviewed by Keyera's Disclosure Committee,” demonstrating multiple layers of internal review. It also highlights the Board’s new “Governance and Sustainability Committee” which is tasked with “overseeing of our external relations practices, including regarding government relations, community engagement and social investment,” underscoring formal governance. However, we found no evidence of a dedicated climate-lobbying audit or external report evaluating lobbying alignment, suggesting that while roles, reporting and review processes are well-defined for both direct and indirect lobbying, there is no public in-depth alignment assessment. View Sources	B

Overall Assessment

Analysis

Score

Strong

Keyera has implemented a multi-channel governance process to align its policy influencing activities with its climate change strategy. It reports that “Our External Affairs Team … reports directly to Senior Vice President, Sustainability, External Affairs & General Counsel who has oversight of and ensures corporate alignment of Keyera’s policy engagements, industry involvement and external relations activities,” and indicates that this role also oversees “Keyera’s membership in industry associations.” The company explains that “The General Manager, External Relations, had oversight of Keyera’s semi-annual reporting to the Alberta Lobbyists Act,” providing a recurring monitoring mechanism for lobbying activities. Keyera further describes that “Keyera’s Executive team is consulted on climate-related issues and potential adjustments advocacy” and that “these types of disclosures are reviewed by Keyera's Disclosure Committee,” demonstrating multiple layers of internal review. It also highlights the Board’s new “Governance and Sustainability Committee” which is tasked with “overseeing of our external relations practices, including regarding government relations, community engagement and social investment,” underscoring formal governance. However, we found no evidence of a dedicated climate-lobbying audit or external report evaluating lobbying alignment, suggesting that while roles, reporting and review processes are well-defined for both direct and indirect lobbying, there is no public in-depth alignment assessment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Keyera Corp provides a highly transparent picture of its climate-policy lobbying. It names numerous specific measures it has worked on, including the “Technology Innovation Emission Reduction (TIER) regulation,” “Clean Fuel Regulation,” the “Investment Tax Credit for CCUS,” and the “Federal Methane Regulation Directive 60,” as well as broader files such as mandatory climate-related reporting, carbon tax design, and electricity grid access for renewables. The company also explains exactly how and where it engages: it has “attended round table discussions and engaged one-on-one with government and regulators,” submitted “written feedback to Finance Canada” on the CCUS tax credit, and works indirectly through industry bodies like the Canadian Association of Petroleum Producers, with all lobbying recorded under the Alberta Lobbyists Act. Finally, Keyera sets out concrete objectives for each file—for example it is “supportive of TIER, and we have requested further detail on treatment of high-performance benchmarking and tightening rates,” advocates “stackability of credit generation capacity between clean fuel regulation and TIER,” and urges Finance Canada to benchmark the CCUS ITC against the U.S. IRA’s Section 45Q “to increase Canada’s competitiveness.” These detailed positions, mechanisms, and policy references demonstrate a comprehensive level of disclosure on its climate lobbying activities.	A