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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Enbridge Inc. provides a wide-ranging and detailed picture of its climate-policy advocacy. It names numerous specific measures it has engaged on, including federal and provincial carbon pricing frameworks such as the “Output Based Pricing System (OBPS) Regulations,” Ontario’s “Emissions Performance Standards,” the Canadian “Clean Fuel Standard,” the forthcoming “Canada Clean Electricity Regulation,” U.S. “New Source Performance Standards for methane emissions,” the “Inflation Reduction Act,” and permitting-reform proposals before the U.S. Congress, as well as its applications under Alberta’s carbon-hub selection process and the Ontario “Oil, Gas and Salt Resources Act.” The company is equally explicit about how and with whom it lobbies: it describes “submitting comment letters to the Canadian Securities Administrators and the U.S. Securities Exchange Commission,” “several meetings with representatives from the Ministry of the Environment, Conservation and Parks,” participation in government “Technical Working Group and Multi-Stakeholder Working Group” sessions on the Clean Fuel Standard, filing lobbying reports with the Canadian and U.S. registries, and working “with ECCC, through the CGA, to develop an intensity metric,” as well as a host of indirect channels through trade bodies such as the American Clean Power Association and the American Gas Association. Finally, Enbridge is clear about what it wants these interventions to achieve: it seeks “harmonization of the Ontario GHG reporting program with the federal GHG reporting program,” carbon-pricing designs that “encourage transparency, equity and cost-effective and competitive approaches to emissions reduction,” “a streamlined, predictable permitting process to accelerate the development of clean energy infrastructure,” and support for IRA provisions that incentivise carbon capture, hydrogen, RNG, wind and solar. Specific requests such as providing “more detailed definitions for ‘emergency’” in the Clean Electricity Regulation and establishing a “market mechanism linked with Canada’s Offset Credit System” further illustrate the precision of its policy objectives. Taken together, these disclosures demonstrate a comprehensive level of transparency across the policies the company targets, the mechanisms it deploys, and the outcomes it is pursuing.
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4
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Enbridge discloses a well-structured governance process that reaches from policy design through to continual monitoring of both direct and indirect climate lobbying activities. The company has issued an “expanded Climate Lobbying Report” that “provides greater transparency about how our lobbying activities align with the goals of the Paris Agreement, describes our approach to climate lobbying, and provides a clear framework that addresses any misalignment between the climate positions of trade associations we are members of and the goals of the Paris Agreement,” and it supplements this with “additional trade association policy reviews and lobbying disclosures, including a specific climate-related lobbying report.” That review is described in detail: in 2023 “we conducted a review of how eight key trade associations’ climate-related activities and positions align with ours,” using a methodology that “involved reviewing current policy statements… [and] compar[ing] these against Enbridge positions to determine whether sufficient alignment exists to justify continued support.” Management commits that “we are committed to continuing to actively monitor our memberships, participation, and alignment,” signalling an ongoing rather than one-off process. Direct lobbying is also covered: “Our lobbying activities support the transition to a lower-carbon economy and our net-zero commitment serves as a guidepost,” and “Our direct and indirect activities that influence policy are guided by our Corporate Climate Policy, Statement on Business Conduct and our Political Contributions Policy,” with an “ethics and compliance program” that delivers “ongoing communication, training, monitoring and enforcement.” Oversight is clearly assigned: “The Board and the Sustainability Committee also have stewardship over political lobbying activities,” while “senior managers and corporate subject-matter experts provide regular briefings to the Sustainability Committee of our Board,” and the Board “reviews and approves the Company’s strategic plan… including energy transition and progress toward our net-zero goals.” The Sustainability Committee “monitors developments related to climate change and how Enbridge is responding to new regulatory and market dynamics,” and in 2023 “provided feedback to management regarding key regulatory developments.” Finally, the company reports that it “reviewed and approved an updated Political Contributions Policy to further align participation in the political process to the Company’s core values,” indicating board-level sign-off on the policy infrastructure that governs lobbying. The presence of a dedicated, publicly available climate-lobbying report, a defined methodology and iterative review of trade-association alignment, explicit coverage of direct lobbying, and named board-level oversight together indicate strong and transparent governance of climate-related lobbying, with only limited disclosure gaps (for example, no public example of terminating a membership) noted.
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4
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