Booking Holdings Inc

Booking Holdings' disclosures suggest that its Board of Directors and senior committees receive regular briefings on public affairs and sustainability, yet the company does not disclose any dedicated climate-lobbying governance framework. For example, it "report[s] our advocacy activities to the European Union Transparency Register (and similar public databases)" and "make[s] positions transparent on a public policy blog," and "annually present[s] our public affairs strategy to our Board of Directors and provide written updates throughout the year as required," indicating that the Board has visibility into its lobbying. However, there is no policy or process to ensure that lobbying aligns with its climate objectives, and when asked about alignment with the Paris Agreement, the company replied plainly "No, and we do not plan to have one in the next two years." Additionally, while the company notes that "Our Sustainability Steering Committee is responsible for signing off on Booking Holdings' overall sustainability strategy, goals, and deliverables," we found no evidence that this committee or any other body oversees or manages the alignment of its direct or indirect lobbying activities with its climate commitments. As a result, the organization provides limited transparency on how it governs or aligns its lobbying with its stated sustainability or climate goals.