Valero Energy Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Valero discloses a multi-layered process that actively governs both its own advocacy and its trade-association relationships and makes the results public, indicating comprehensive governance. The company states that its Policy on Political Contributions, Lobbying and Trade Associations guides engagement and that the CEO and General Counsel review and approve recommendations by Valeros government affairs team on political contributions and lobbying activities, while the Board-level Sustainability and Public Policy Committee receives, at least once annually, a formal report from management on these activities. Oversight of climate aspects is reinforced as the committee is charged with political issues, including political contributions and lobbying activities, and the General Counsel has direct reporting duties to the Nominating/Governance and Public Policy Committee. In addition to this structure, Valero publicly releases an Annual climate lobbying report, including alignment analysis of indirect lobbying through trade associations, noting that it conducted a review of climate lobbying activities and concluded that certain trade associations with lobbying activities were substantially aligned with, or were in the process of aligning with, Valeros vision of providing affordable and sustainable energy while reducing GHG emissions. The disclosure that the company found the following trade associations substantially aligned with, or are in the process of being aligned with, our vision demonstrates an active mechanism for addressing misalignment, and the published report covers indirect lobbying in depth. Direct lobbying is also captured through the Boards recent reviews of political spending and lobbying, and the full Board regularly receives updates on political, reputational, ESG and sustainability, HSE, cybersecurity and IT, public policy and climate-related risks, showing routine monitoring. While Valero currently lacks a Paris-alignment commitment, the publicly available alignment analysis, explicit policies, and clearly named oversight bodies together signal strong transparency, a defined monitoring cycle, and board-level accountability for ensuring that its climate-related lobbying activities remain aligned with its stated strategy. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

Valero discloses a multi-layered process that actively governs both its own advocacy and its trade-association relationships and makes the results public, indicating comprehensive governance. The company states that its Policy on Political Contributions, Lobbying and Trade Associations guides engagement and that the CEO and General Counsel review and approve recommendations by Valeros government affairs team on political contributions and lobbying activities, while the Board-level Sustainability and Public Policy Committee receives, at least once annually, a formal report from management on these activities. Oversight of climate aspects is reinforced as the committee is charged with political issues, including political contributions and lobbying activities, and the General Counsel has direct reporting duties to the Nominating/Governance and Public Policy Committee. In addition to this structure, Valero publicly releases an Annual climate lobbying report, including alignment analysis of indirect lobbying through trade associations, noting that it conducted a review of climate lobbying activities and concluded that certain trade associations with lobbying activities were substantially aligned with, or were in the process of aligning with, Valeros vision of providing affordable and sustainable energy while reducing GHG emissions. The disclosure that the company found the following trade associations substantially aligned with, or are in the process of being aligned with, our vision demonstrates an active mechanism for addressing misalignment, and the published report covers indirect lobbying in depth. Direct lobbying is also captured through the Boards recent reviews of political spending and lobbying, and the full Board regularly receives updates on political, reputational, ESG and sustainability, HSE, cybersecurity and IT, public policy and climate-related risks, showing routine monitoring. While Valero currently lacks a Paris-alignment commitment, the publicly available alignment analysis, explicit policies, and clearly named oversight bodies together signal strong transparency, a defined monitoring cycle, and board-level accountability for ensuring that its climate-related lobbying activities remain aligned with its stated strategy.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Valero Energy Corp provides only limited insight into its climate-related lobbying. The company notes that it “continually engage[s] with shareholders and other stakeholders and monitor[s] current and proposed climate and environmental-related policies, laws and regulations,” and it references policy areas such as vehicle-mileage standards, electric-vehicle mandates, carbon taxes, and named programs like the Renewable Fuel Standard, California’s Low Carbon Fuel Standard, and Canada’s Clean Fuel Regulations. However, it does not clarify whether these references reflect actual attempts to influence those measures, nor does it describe the specific bills or regulatory proposals on which it has taken a position. The disclosure is similarly silent on how it lobbies: it offers no examples of letters, meetings, public comments, or trade-association activity, and it does not identify the government bodies or officials it seeks to influence. Finally, Valero limits itself to broad statements of intent—such as aiming to “help achieve GHG emissions reduction ambitions” or “pursue opportunities to further lower the CI of many of our products”—without articulating concrete policy changes, targets, or amendments it is advocating. Collectively, these omissions leave readers with only a general sense that the company tracks climate policy and may engage when “appropriate,” but little transparency about the substance, methods, or objectives of any lobbying it undertakes.	D