Norfolk Southern Corp

Attach commitment or position statement(s)[…]In May 2021, Norfolk Southern Corporation's shareholders passed a resolution at our annual shareholder's meeting asking that we evaluate and publish a report describing if, and how, our lobbying activities (direct and through trade associations and other organizations) align with the goals of the Paris Climate Agreement and risks presented by any misalignment.
Following the shareholder vote, we engaged with shareholders and asked for their feedback to best understand what shareholders wanted included in this report. Beyond the explicit requests set forth in the resolution, our shareholders generally communicated that they were looking for an understanding of our efforts in the climate area, transparency as to our activities concerning climate lobbying, and the oversight of such activities. We took these shareholders concerns into account when drafting this attached report. This report is aligned with NS' climate change strategy.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]NS' Government Relations team seeks to educate and inform public officials about issues important to NS' business, and it supports public officials and candidates whose views match those of Norfolk Southern. By doing so, Norfolk Southern furthers public policy goals that are consistent with its business, values, and strategies, and as a result, ensures our engagement activities are consistent with our overall climate change strategy.
The processes NS has in place to ensure this are as follows. To advocate our position, the corporation relies on government relations professionals, assisted as needed by subject matter experts. Norfolk Southern's adopted corporate procedure states that only authorized employees and contract lobbyists may engage in lobbying activities, as defined by the appropriate jurisdiction, on behalf of the corporation. In addition, the procedure requires a corporation employee who has engaged in lobbying on behalf of the corporation to report the time spent on such lobbying, and any associated expenses, immediately following the close of the calendar quarter in which such lobbying occurred. The procedure further requires that persons who engage in lobbying on behalf of the corporation comply with all applicable legal requirements.
NS continues to have ongoing dialogue with regulators and policymakers. As part of its oversight role, the Governance and Nominating Committee of the corporation's Board of Directors reviews, at least annually, the corporation's political contributions, including spending related to trade associations and other tax-exempt organizations.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes