American Water Works Co Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	American Water discloses several internal controls that give it a structured, but still partial, approach to governing climate-related advocacy. It explains that “only SMEs and those authorized by the American Water Communications Department, are permitted to engage with and respond to elected officials, policy makers and regulators to help make certain that all public engagement messaging is consistent with the Company position and strategy,” showing a concrete gate-keeping mechanism for direct lobbying. The company adds that “our SMEs have been trained on conveying specific climate variability messaging related to their areas of expertise” and that such messaging is delivered to “elected officials, policy makers and regulators,” indicating a process designed to align climate content in its outreach. Oversight is mentioned at board level: “The Safety, Environmental, Technology & Operations Committee of the Board directly oversees ESG matters and maintains alignment with overall operations,” and executive sign-off is implied through a materiality assessment that was “approved by the Company’s Executive Leadership.” Together these disclosures demonstrate a policy and named oversight bodies for ensuring that direct engagement reflects the company’s climate strategy, which indicates moderate governance. However, the company “communicate[s] regularly… with trade associations” yet provides no description of how it reviews or manages the climate positions of those associations, nor does it publish any lobbying-alignment audit or Paris-aligned commitment; consequently, the governance framework for indirect lobbying remains undisclosed and the overall process lacks external transparency and formal monitoring criteria. View Sources	C

Overall Assessment

Analysis

Score

Moderate

American Water discloses several internal controls that give it a structured, but still partial, approach to governing climate-related advocacy. It explains that “only SMEs and those authorized by the American Water Communications Department, are permitted to engage with and respond to elected officials, policy makers and regulators to help make certain that all public engagement messaging is consistent with the Company position and strategy,” showing a concrete gate-keeping mechanism for direct lobbying. The company adds that “our SMEs have been trained on conveying specific climate variability messaging related to their areas of expertise” and that such messaging is delivered to “elected officials, policy makers and regulators,” indicating a process designed to align climate content in its outreach. Oversight is mentioned at board level: “The Safety, Environmental, Technology & Operations Committee of the Board directly oversees ESG matters and maintains alignment with overall operations,” and executive sign-off is implied through a materiality assessment that was “approved by the Company’s Executive Leadership.” Together these disclosures demonstrate a policy and named oversight bodies for ensuring that direct engagement reflects the company’s climate strategy, which indicates moderate governance. However, the company “communicate[s] regularly… with trade associations” yet provides no description of how it reviews or manages the climate positions of those associations, nor does it publish any lobbying-alignment audit or Paris-aligned commitment; consequently, the governance framework for indirect lobbying remains undisclosed and the overall process lacks external transparency and formal monitoring criteria.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	American Water Works has provided only limited insight into its climate-related lobbying. It does identify a concrete piece of legislation it supported—the Infrastructure Investment and Jobs Act—and explains that the Act includes funding for water infrastructure, lead-service-line replacement and PFAS treatment, indicating some clarity around what it lobbied on. Beyond naming this single statute, however, the company gives no detail on how it sought to influence the bill or any other policy: it simply says it “engag[es] with policymakers at every level of government” and participates in non-partisan partnerships, without specifying whether this involves meetings, written submissions, coalition work or other tactics, nor does it identify any particular agencies, legislators or jurisdictions targeted. Likewise, the company only states broad aspirations—such as supporting regulations that enable safe, affordable, high-quality water service, improving infrastructure efficiency and reducing emissions—without spelling out the precise regulatory changes, amendments or quantitative goals it is pursuing. Because the disclosures stop short of outlining concrete mechanisms or clearly defined policy outcomes, the overall transparency of its climate-policy lobbying remains limited.	D