Keyera Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Keyera Corp. has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has explicitly named specific policies it has engaged with, such as the "Technology Innovation Emission Reduction (TIER)" regulation, "Clean Fuel Regulation," "Federal Methane Regulation Directive 60," and the "Investment Tax Credit for CCUS." It has also provided detailed information about the focus areas of these policies, including "carbon tax," "electricity grid access for renewables," and "methane emissions," along with their geographical scope, such as regional and national levels within Canada. Keyera has been equally transparent about its lobbying mechanisms, detailing its direct engagement through roundtable discussions, one-on-one meetings with government and regulators, and written feedback to Finance Canada. It has also disclosed indirect lobbying through trade associations like the Canadian Association of Petroleum Producers (CAPP) and outlined its compliance with oversight mechanisms, such as semi-annual reporting to the Alberta Lobbyists Act. Furthermore, the company has clearly articulated the outcomes it seeks, including advocating for "stackability of credit generation capacity between clean fuel regulation and TIER," recommending that "Finance Canada evaluate the CCUS ITC against the U.S. IRA's Section 45Q," and supporting the TIER regulation with minor exceptions. Keyera has also confirmed the alignment of its lobbying efforts with the Paris Agreement, further demonstrating its commitment to transparency and accountability in its climate policy engagements.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Keyera demonstrates a defined governance process to ensure alignment of its climate lobbying activities with its climate change strategy. The company states that "Keyera works to ensure direct and indirect activities that influence policy are aligned with our climate change strategy through several channels." Oversight is clearly established, with the External Affairs Team, Sustainability Team, and Communication Team reporting to the Senior Vice-President, General Counsel, who has "oversight (including ensuring alignment with climate strategy and position) on Keyera's policy engagements, industry involvement and external relations activities." Additionally, the SVP oversees "Keyera's semi-annual reporting to the Alberta Lobbyists Act," which includes details on lobbying activities, funding requested, and funding received. The governance structure also involves consultation with Keyera's Executive team on climate-related issues and advocacy adjustments, as well as review of disclosures by the Disclosure Committee. Furthermore, Keyera has Political Activities Guidance outlined in its Code of Business Conduct Policy, which restricts political contributions unless approved by senior management. This indicates strong governance with monitoring mechanisms and responsible parties identified.	3