Canadian Pacific Kansas City Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Canadian Pacific Kansas City Ltd has instituted formal committees to govern its climate-related policy engagement, though the framework does not fully clarify how lobbying activities are managed across all channels. The company explains that its “Climate Commitments, Climate Strategy and overall sustainability policies are reviewed with CP’s Executive team and the Board level Risk and Sustainability (RSC) Committee,” and that its “cross-functional Sustainability Steering Committee (SSC) oversees the implementation, monitoring and reporting of sustainability and climate change performance.” It further notes that a key component of its Climate Strategy is to drive internal alignment while engaging suppliers, customers, rail transportation peers and policymakers to help lead industry-wide change through “strategic engagements … including topics related to cap and trade, carbon taxes, fuel efficiency standards, renewable fuel standards and emissions reporting programs.” These processes ensure that direct engagements with policymakers are subject to executive and board level review and approval. However, the company does not disclose a specific governance policy or process for indirect lobbying through trade associations, nor does it name an individual accountable for climate lobbying oversight. We found no evidence of procedures to evaluate or manage potential misalignment in association memberships or third-party advocacy, indicating moderate but incomplete governance of its lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Canadian Pacific Kansas City Ltd has instituted formal committees to govern its climate-related policy engagement, though the framework does not fully clarify how lobbying activities are managed across all channels. The company explains that its “Climate Commitments, Climate Strategy and overall sustainability policies are reviewed with CP’s Executive team and the Board level Risk and Sustainability (RSC) Committee,” and that its “cross-functional Sustainability Steering Committee (SSC) oversees the implementation, monitoring and reporting of sustainability and climate change performance.” It further notes that a key component of its Climate Strategy is to drive internal alignment while engaging suppliers, customers, rail transportation peers and policymakers to help lead industry-wide change through “strategic engagements … including topics related to cap and trade, carbon taxes, fuel efficiency standards, renewable fuel standards and emissions reporting programs.” These processes ensure that direct engagements with policymakers are subject to executive and board level review and approval. However, the company does not disclose a specific governance policy or process for indirect lobbying through trade associations, nor does it name an individual accountable for climate lobbying oversight. We found no evidence of procedures to evaluate or manage potential misalignment in association memberships or third-party advocacy, indicating moderate but incomplete governance of its lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Canadian Pacific Kansas City Ltd provides a relatively detailed picture of its climate-policy lobbying. It identifies two specific federal initiatives it has engaged on—the Canada Clean Fuel Standard and the Federal Output-Based Pricing System established under the Greenhouse Gas Pollution Pricing Act—clearly situating both within the national Canadian context. The company also explains how it seeks to influence these measures, noting that it works through the Railway Association of Canada, submits comments directly to federal regulators, and coordinates these efforts through an internal cross-functional team, while explicitly naming the Government of Canada as its lobbying target. Importantly, the railway sets out the concrete changes it is advocating: allowing deductions for capital expenditures that reduce greenhouse-gas emissions, directing carbon-pricing revenues toward rail programmes that encourage low-emissions transport, and improving transparency for fuel users about renewable content to address locomotive performance and warranty concerns. By disclosing the specific policies, the channels it uses, the policymakers it addresses, and the precise outcomes it seeks, the company demonstrates a strong level of transparency around its climate lobbying activities.	B