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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Host Hotels & Resorts provides a high level of transparency around its climate-policy lobbying. It names multiple identifiable policies it has worked on, including “Washington, D.C.’s Building Energy Performance Standards (BEPS) Program,” the proposed “building energy performance legislation in Montgomery County,” and the “Seattle Building Energy Performance Standards (BPS),” all of which are clearly climate-related. The company also describes how it lobbies and whom it targets: it “directly engages with policy makers at the local level,” has “joined other REITs in providing comments to inform the enforcement” of the D.C. BEPS, submitted “data and analysis for hotels” as a case study, and collaborates with the “Seattle government and Washington Hospitality Association” as well as broader trade bodies such as Nareit and the Real Estate Roundtable. Finally, Host is explicit about the outcomes it seeks. It “supports the role of BEPS to help meet the energy and climate goals of the Sustainable DC plan — to reduce greenhouse gas emissions and energy consumption by 50% by 2032,” backs the Seattle BPS objective “to reduce greenhouse gas emissions 27% by 2050,” and has asked for “adjustments to emissions targets for hotel building types” so that standards reflect differences in hotel amenities. It also endorses LEED and other green-building requirements in its redevelopment projects. Together, these disclosures demonstrate comprehensive transparency on the policies, mechanisms, and objectives of the company’s climate-related lobbying.
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4
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| Overall Assessment |
Comment |
Score |
| Moderate |
Host Hotels & Resorts Inc. maintains some structured oversight of its climate policy engagements, particularly by governing its indirect lobbying through trade associations: its Code of Business Conduct and Ethics states that "company funds may not be used to contribute to candidates, political party committees or political action committees," and "we engage on public policy indirectly through our affiliations with trade associations, who have publicly disclosed priorities that are aligned with our overall climate change strategy." Its Corporate Responsibility Core Team, "led by the vice president of energy and sustainability," "monitors trade association memberships; reviews and monitors these trade associations’ positions, including alignment with the Paris Agreement; and may also report on climate-related positions and activities for certain trade associations in which Host is a member of," with final oversight provided by the Nominating, Governance and Corporate Responsibility Committee of the Board, which "has reviewed and approved the Environmental Policy." However, Host does not disclose a parallel governance mechanism to ensure alignment of its direct lobbying efforts—such as engagement with local municipalities on building performance standards—with its overarching climate strategy, nor does it publish a dedicated climate-lobbying audit or evidence of board-level sign-off specifically for its advocacy activities, indicating that its approach to direct climate lobbying remains unspecified.
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2
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