Delta Air Lines Inc

Delta Air Lines discloses a detailed and multi-layered governance system that specifically governs both its direct and indirect climate-lobbying activities. The company publishes an annual "Climate Lobbying Report" which "details the company's global advocacy activities and policy engagements - both direct and indirect - that support and complement our Paris Agreement-aligned climate goals" and within which "this section of the report also assesses these climate lobbying activities for alignment with our net-zero climate goals and policy principles." Oversight responsibilities are clearly assigned: "Management of our overarching advocacy and regulatory compliance activities is the responsibility of our Executive Vice President and Chief Legal Officer in conjunction with our Senior Vice President, Government Affairs, and our Vice President, State and Local Government Affairs," while at the board level "the Corporate Governance Committee of the Board also receives formal reports on our political activities" and "reviews and approved" the Climate Lobbying Report. Day-to-day leadership is provided by "the new role of Vice President, Government Affairs - Sustainability... ensuring alignment between the company's climate goals and its climate lobbying activities." The company explains that it "periodically assess[es] the alignment of Delta and Monroe's trade associations' climate change positions with our own... In 2023, we assessed the activities of key associations, including IATA, A4A, the Business Roundtable and American Fuel and Petrochemical Manufacturers," and elaborates a two-step methodology that examines both stated positions and specific lobbying actions. Delta also notes that where misalignment arises "we have in the past taken - and may in the future take - independent actions to mitigate risks an association's actions may present to our strategy." This combination of a publicly available alignment assessment, explicit processes for reviewing trade-association positions, dedicated management roles, and routine board oversight indicates a comprehensive and transparent governance framework for climate-lobbying alignment. We found no evidence that any required element of monitoring, oversight or disclosure is missing from the company's public materials, which indicates very strong governance.