Norfolk Southern Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Norfolk Southern Corp has implemented a formal process to govern its lobbying activities, with a corporate procedure that states “only authorized employees and contract lobbyists may engage in lobbying activities” and requires those individuals to “report the time spent on such lobbying, and any associated expenses” on a quarterly basis, ensuring basic oversight of its advocacy efforts. Its Government Relations team “seeks to educate and inform public officials about issues important to NS’ business … and as a result, ensures our engagement activities are consistent with our overall climate change strategy,” illustrating a mechanism to align direct lobbying with its climate goals. The Governance and Nominating Committee of the Board of Directors provides named oversight by “reviewing, at least annually, the corporation’s political contributions, including spending related to trade associations and other tax-exempt organizations,” and the company has committed to publicly evaluate “if, and how, our lobbying activities (direct and through trade associations and other organizations) align with the goals of the Paris Climate Agreement,” even affirming a public position “to conduct your engagement activities in line with the goals of the Paris Agreement.” However, beyond expenditure reporting, the company does not disclose a structured procedure for assessing or realigning the policy positions of trade associations with its climate objectives. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Norfolk Southern Corp has implemented a formal process to govern its lobbying activities, with a corporate procedure that states “only authorized employees and contract lobbyists may engage in lobbying activities” and requires those individuals to “report the time spent on such lobbying, and any associated expenses” on a quarterly basis, ensuring basic oversight of its advocacy efforts. Its Government Relations team “seeks to educate and inform public officials about issues important to NS’ business … and as a result, ensures our engagement activities are consistent with our overall climate change strategy,” illustrating a mechanism to align direct lobbying with its climate goals. The Governance and Nominating Committee of the Board of Directors provides named oversight by “reviewing, at least annually, the corporation’s political contributions, including spending related to trade associations and other tax-exempt organizations,” and the company has committed to publicly evaluate “if, and how, our lobbying activities (direct and through trade associations and other organizations) align with the goals of the Paris Climate Agreement,” even affirming a public position “to conduct your engagement activities in line with the goals of the Paris Agreement.” However, beyond expenditure reporting, the company does not disclose a structured procedure for assessing or realigning the policy positions of trade associations with its climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Norfolk Southern Corp offers only a limited window into its climate-related lobbying. It identifies the broad policy area it works on—"Energy efficiency requirements" in the United States—but does not name any particular bill, regulation, or rule, so readers cannot pinpoint the exact measures being influenced. The company does specify its method, noting that "NS energy efficiency advocacy is coordinated through the Association of American Railroads," signalling indirect engagement through a trade association, yet it gives no detail on which federal agencies or lawmakers are approached. The desired outcomes are somewhat clearer: it seeks "government understanding of railroads’ improved fuel efficiency metrics" and urges the "cautious imposition of new requirements that may support the increased efficiency," a position it frames as "Support with no exceptions." While these statements reveal the direction of the company’s advocacy, the absence of concrete policy names or clearly identified lobbying targets means its overall transparency remains modest.	D