CMS Energy Corp

CMS Energy has implemented a governance framework that explicitly integrates climate policy into its lobbying activities through a "set of principles to guide its perspectives on climate change policy proposals," including positions "consistent with policies that limit global warming to no more than 2 degrees Celsius, and preferably 1.5 degrees," which "are implemented on a policy-by-policy basis by at least two internal working teams known as the Regulatory Policy Team and the Carbon Council and Policy Team." Oversight resides with its Board of Directors, which "oversees our political engagement policies, programs and practices," and the Governance, Sustainability and Public Responsibility Committee, to which the senior vice president for governmental, regulatory and public affairs "reports the prior year's expenditures for political purposes" annually. The company also manages its indirect lobbying by tracking trade association dues and reserves the right to "abstain or withdraw membership" from organizations whose positions conflict with its values, and discloses the non-deductible portion of those dues. While this structure demonstrates clear oversight and policy alignment for climate-related advocacy, CMS Energy does not disclose a dedicated climate-lobbying review or publicly available audit, and the specific procedures by which its working teams translate climate principles into direct lobbying strategies are not fully detailed.