Alphabet Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Alphabet is highly transparent about its climate-policy lobbying. The company lists numerous specific measures it has worked on, including the 24/7 carbon-free energy goal that was adopted in the U.S. Federal Sustainability Plan, the Clean Energy for America Act, the CLEAN Future Act, the Infrastructure Investment and Jobs Act, the Clean Electricity Performance Program in the Build Back Better Act, the Inflation Reduction Act, the U.S. Department of Energy’s draft Clean Hydrogen Production Standard, and the U.S. SEC’s proposed climate-risk disclosure rule, as well as European initiatives such as the EU Green Deal and reforms to unlock corporate power-purchase agreements. Alphabet also describes in detail how it lobbies and whom it targets. Its energy and public-policy teams meet directly with the White House, members of Congress, state governors, EU institutions and other national governments; it files formal comments to agencies such as the U.S. Department of Energy and the SEC; it sends joint letters to European Commissioners; and it works through industry bodies including the RE-Source Platform, WindEurope, Solar Power Europe, ACORE, ACPA, REBA and the Japan Climate Leaders Partnership. Finally, the company is explicit about the outcomes it seeks. It advocates the federal adoption of 24/7 carbon-free power for government facilities, expansion of clean-energy tax incentives, removal of barriers to corporate power-purchase agreements in Europe, stronger hourly and geographic matching criteria in U.S. hydrogen rules, and consistent, comparable climate-risk reporting for investors. It links these positions to its overall goal of accelerating a zero-carbon electricity system and enabling its own carbon-free operations. Altogether, Alphabet’s disclosures provide clear, specific and comprehensive insight into the policies it engages on, the channels it uses, and the results it is pursuing. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Alphabet Inc has a defined governance framework for its policy engagement, anchored by a “well-established compliance program and multi-layered oversight structure” led by its “Global Vice President of Government Affairs and Public Policy” with “additional input from our Chief Legal Officer,” and regular updates to both the Audit Committee and full Board. On climate policy matters, “all activities related to engagement on climate policy are coordinated and managed by designated members of our operations team,” who “coordinate the drafting and review of all public-facing content related to our overall energy, sustainability and climate change strategy,” with materials “tracked centrally for reference and use by other employees” to maintain consistency. These designated employees “ultimately report to our Chief Legal Officer,” and “sustainability teams throughout the organization use this team for review to ensure consistency with our overall climate change strategy.” Alphabet also confirms a “public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” We found no evidence of a process to assess or align its indirect lobbying through industry associations or a dedicated audit of its climate-related lobbying activities. 2