Chevron Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Chevron provides an extensive and detailed picture of its climate-policy lobbying activities. The company names numerous individual measures it has worked on, including EPA’s proposed methane rules ("Docket ID Number: EPA-HQ-OAR-2021-0317"), the Federal Acquisition Regulation proposal on greenhouse-gas disclosure (FAR Case 2021-015), the Council on Environmental Quality’s Phase-2 NEPA revisions, California Senate Bill X1-2 on refinery margins, the 2023-2028 National Outer Continental Shelf Leasing Program, and Australia’s Future Gas Strategy consultation paper, among others. It also explains exactly how it engages: submitting formal comment letters and electronic filings through Regulations.gov, sending a letter from its President of Americas Products to the California Energy Commission, providing written input to BOEM and the FAR Council, meeting with U.S. federal and state agencies, and working indirectly through trade associations such as API, AFPM, BRT and the U.S. Chamber of Commerce. These disclosures consistently identify the policymaking bodies being addressed—e.g., “The Honorable Michael S. Regan, Administrator” of the EPA, the CEQ Chair, the California Energy Commission, BOEM officials, and Australian federal departments—demonstrating clarity on both mechanism and target. Chevron is equally explicit about what it wants to achieve: it calls for “economy-wide carbon pricing as the primary policy tool”, presses for “performance-based” methane regulations that incorporate advanced detection technologies, seeks to “streamline the NEPA review process”, urges BOEM to hold “not less than eleven” Gulf of Mexico lease sales, and asks California to reject SB X1-2 because “an ill-defined and arbitrary maximum margin for refiners will not lower gasoline prices.” By detailing multiple policies, the channels it uses to influence them, and the concrete regulatory changes or safeguards it is advocating, Chevron demonstrates a high level of transparency in its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Chevron has established a comprehensive governance framework for climate-related lobbying, integrating public reporting, board and executive oversight, formal review processes, and clear lines of accountability. It builds on our 2020 Climate Lobbying Report by updating the lobbying and trade association webpage that includes a detailed description of our policies, processes and oversight, demonstrating a dedicated channel for evaluating and publishing its advocacy alignment. Oversight is led at the board level by the Public Policy and Sustainability Committee, which reviews Chevrons political activities, including how its direct and indirect lobbying on climate issues supports Chevrons climate strategy and reflects on the Companys reputation, and at the executive level by the Global Issues Committee (GIC), ensuring management-level monitoring of climate policy and lobbying. Governance procedures require that the committee annually reviews the policies, procedures and expenditures related to the Corporations political contributions and lobbying to assess the value of these activities and ensure alignment with Chevrons positions and interests, while Corporate Affairs centrally manages a process to gather and report lobbying activities which includes: officials contacted, matters lobbied, employee time, expenses, gifts and political contributions depending on the jurisdictions requirements. Senior executives review trade association memberships to consider value to the business, subjecting those with lobbying budgets to a rigorous budgeting process, and employees engage in mandated online training on political compliance. Company policies designate Chevrons vice president of Corporate Affairs as responsible for an effective political engagement program, indicating strong alignment mechanisms for both direct and indirect lobbying activities.	4