Valero Energy Corp

Lobbying Governance

AI Extracted Evidence Snippet Source

Reporting political disclosures, including contributions, lobbying and trade associations. [...] Annual climate lobbying report, including alignment analysis of indirect lobbying through trade associations and Valero's vision of providing affordable fuels while reducing GHG emissions. [...] Board Oversight — The CEO and the General Counsel review and approve recommendations by Valero's government affairs team on political contributions and lobbying activities. Additionally, the Sustainability and Public Policy Committee is responsible for assisting the Board with oversight of Valero's political contributions and lobbying activities and receives, at least once annually, a formal report from management on these activities. [...] Climate-lobbying Alignment Analysis — We 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, Valero's vision of providing affordable and sustainable energy, while reducing GHG emissions.

https://www.valero.com/sites/default/files/valero-documents/2023_ESG_Report.pdf

Valero's board of directors ("Board") considers oversight of Valero's risk management to be a responsibility of the full Board. [...] The full Board regularly receives from management, and discusses at Board meetings, updates on operational, financial, market, legal, regulatory, strategic, human capital, political, reputational, ESG and sustainability, HSE, cybersecurity and IT, public policy and climate-related risks facing Valero. From time to time, the Board also requests reports on areas of special or current relevance. For example, the full Board recently conducted reviews with management of: [...] (vi) political spending and lobbying, [...] The oversight of risk is shared between the full Board and its committees. The full Board (or appropriate Board committee) regularly receives reports from management to enable the Board (or committee) to assess Valero's risk identification, risk management and risk mitigation strategies. When a report is vetted at the committee level, the chair of that committee thereafter reports on the matter to the full Board. This enables the Board and its committees to coordinate the Board's risk oversight role. [...] Our Sustainability and Public Policy Committee is responsible for assisting the Board with oversight of (i) corporate responsibility and reputation management, (ii) HSE matters, (iii) sustainability and climate-related risks and opportunities, (iv) social, community and public policy strategies and initiatives, (v) political issues, including political contributions and lobbying activities, and (vi) compliance with legal and regulatory requirements for the operations of the company.

https://www.valero.com/sites/default/files/valero-documents/2022-TCFD-Report-FINAL-digital-spreads.pdf

The Nominating/Governance and Public Policy Committee is composed of five independent directors with an effective mix of backgrounds, knowledge and skills. The committee is positioned to effectively assist the Board in its oversight responsibilities with respect to corporate governance, Board membership and environmental, social and governance (ESG) matters. Those ESG matters include, but are not limited to, climate-related risks and opportunities; health, safety and environmental performance; public policy; political contributions; and corporate responsibility. [...] Valero's senior management team assesses and manages climate-related risks and opportunities through an interdisciplinary approach that coordinates the views of our commercial, operational, regulatory, policy, legal and government affairs groups into long-term strategic planning. This effort is overseen by our Senior Vice President, General Counsel and Secretary who reports to our Chief Executive Officer and has direct reporting duties to the Nominating/Governance and Public Policy Committee. Our Senior Vice President, General Counsel and Secretary has direct management oversight of Health, Safety and Environmental; ESG; Compliance; Risk Management; Government Relations and Legal matters. Each of those areas is actively involved in climate-related management issues.

https://www.valero.com/sites/default/files/valero-documents/2021-TCFD-Report-and-Scenario-Analysis_9-27-21_Spreads.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]We have in place a Policy on Political Contributions, Lobbying and Trade Associations. We believe that constructive participation in the political process in an important means of enhancing shareholder value and promoting good corporate citizenship. It is in the best interest of Valero that federal, state, and local governments understand how their actions impact Valero's business, employees and other stakeholders. To that end, Valero exercises its right to engage in this process through lawful contributions to political parties, candidates, associations, and other political
organizations, consistent with applicable laws and Valero policies.

Regarding climate-related alignment, we recognize that low-carbon fuels will be an increasing part of the energy mix and are leveraging our liquid-fuels platform and operational expertise to invest into high-growth, high-return, low-carbon projects that support this demand. As part of our analysis of sound and effective climate-related policies, we believe any policy should:
- Encourage global participation and prevent the shifting of emissions to less strict or unregulated jurisdictions;
- Promote market-driven solutions in order to drive the most cost-effective options;
- Ensure continued access to reliable and affordable energy;
- Allow for future innovation in science and technology, and corresponding developments in policy;
- Apply across all sectors of the economy; and
- Embrace simplicity to minimize administrative costs.

We may have various reasons for participating and various levels of participation at trade associations, and may not always agree with, or control the lobbying efforts or positions adopted by trade associations. However, in 2021 we found the following trade associations substantially aligned with, or are in the process of being aligned with, our vision of providing affordable and sustainable energy while reducing GHG emissions: See climate-lobbying alignment report at https://esg.investorvalero.com/policy-advocacy/

CDP Questionnaire Response 2022

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]No, and we do not plan to have one in the next two years

CDP Questionnaire Response 2023

As part of our engagement, we may advocate directly or with trade associations on issues that affect our business and the energy industry.

Under the direction of the Chief Executive Officer and the General Counsel, Valero's government affairs team seeks to build relationships and provide information to policy makers, legislators, regulators and other stakeholders on complex legislative and regulatory issues that impact our business and the energy industry.

We engage directly with lawmakers and regulators and participate with trade associations and industry groups to promote informed dialogue and advocate for the best interests of our shareholders, employees, neighbors and other stakeholders. As the world's largest independent refiner and the world's second largest producer of renewable diesel and ethanol, Valero is active in the participation of industry and trade associations at the national, state and local levels. This participation focuses on being an active member of business communities where we work and live, learning and sharing best practices from safety and environmental to labor and technologies, as well as promoting dialogue and advocacy for positions that are in the best interest of our business.

Some trade associations actively lobby on issues that impact their respective membership. As part of the role of management and Board oversight, memberships in trade associations are reviewed to evaluate participation and alignment on matters important to our business.

We realize that some trade associations may have a diverse member base that have viewpoints that not always are aligned with ours. When this occurs, we strive to work with the trade association to express our positions, promote dialogue and reach compromise on common goals. We are cognizant that we do not control indirect lobbying efforts from trade associations, therefore in some instances, we may abstain from supporting an initiative that is not relevant to our business strategy or that diverges from our viewpoints.

To improve access to information about Valero's indirect lobbying activities through trade associations or other organizations of which Valero is a member, Valero posts the Trade Associations report, at least annually: (a) a list of trade associations or other organizations to which Valero makes annual payments of $50,000 or more; and (b) the portion of annual membership dues to trade associations or payments to other organizations of $50,000 or more that were non-deductible under section 162(e) of the Internal Revenue Code, as provided to Valero by the recipients.
At Valero, we recognize that low-carbon fuels will be an increasing part of the energy mix and are leveraging our liquid-fuels platform and operational expertise to invest into high-growth, high-return, low-carbon projects that support this demand.

With more than $5.4 billion invested to date in low-carbon fuels, we are the world's second largest renewable diesel and the world's second largest corn ethanol producer.

As part of our analysis of sound and effective climate-related policies, we believe any policy should:

Encourage global participation and prevent the shifting of emissions to less strict or unregulated jurisdictions;
Promote market-driven solutions in order to drive the most cost-effective options;
Ensure continued access to reliable and affordable energy;
Allow for future innovation in science and technology, and corresponding developments in policy;
Apply across all sectors of the economy; and
Embrace simplicity to minimize administrative costs.

The following list provides information on key trade associations with lobbying efforts to which we paid more than $50,000 in annual dues from July 1, 2023 to June 30, 2024. We may have various reasons for participating and various levels of participation, and may not always agree with, or control the lobbying efforts or positions adopted by these trade associations.

We found the trade associations shown in the table below (that may engage in lobbying activities) to be substantially aligned with, or are in the process of being aligned with, our vision of providing affordable energy while reducing GHG emissions:

AISBL European Petroleum Refiners Association
The European Petroleum Refiners Association (AISBL) states that the EU refining industry is committed to contribute to the EU's climate objectives by continuing to reduce its CO2 emissions and providing the economy and citizens with low-carbon fuels and other products that society needs.

The AISBL mentions that the development of a diversity of energies and energy carriers will give the EU economy flexibility, resilience, and the possibility for the market to select the optimal solution for every sector and use. Liquid fuels, with their unique characteristics, will continue to be employed in many transport fields. Therefore, the EU refining industry has an important and enduring role to play in the energy choices of the future, by providing low-carbon liquid fuels to complement low-carbon electrons, gas and hydrogen as energy carriers. Technology and collaboration across industries will facilitate the production of these low-carbon liquid fuels. The contribution of the EU refining industry can be enhanced by the EU industrial strategy and a policy framework which will enable its transition, while allowing refineries to retain economic viability in the face of a declining domestic market demand and of an increasingly aggressive international competition.
American Fuel and Petrochemical Manufacturers
The American Fuel and Petrochemical Manufacturers (AFPM) states that, along with its members, they are committed to delivering affordable, reliable fuel and petrochemicals products that lift the standards of living for people all over the world; improving the efficiency and sustainability of our operations; offering fuels and petrochemicals that make engines and other products more efficient; and continuing research, innovation, and application of new technologies and products.

AFPM states that policies addressing climate change should be "[b]alanced and measured to improve quality of life, ensuring the long-term economic, energy, and environmental needs of humanity are met[.]" AFPM further emphasizes that such policies be: transparent, applied economy-wide and achievable.
California Business Roundtable
The California Business Roundtable (CBRT) describes itself as a non-partisan organization comprised of the senior executive leadership of the major employers throughout the state – with a combined workforce of more than half a million employees. CBRT states that for more than thirty-five years the CBRT has identified the issues critical to a healthy business climate and provided the leadership needed to strengthen California's economy and create jobs.
California Council for Environmental and Economic Balance
The California Council for Environmental and Economic Balance (CCEEB) describes itself as California's leading voice for strategies that develop a healthy environment and vibrant economy since its founding in 1973 by Governor Edmund G. "Pat" Brown. CCEEB states that it represents a range of industries and interests and relies upon the practice of dialogue and consensus building among its members and other stakeholders to develop solutions that are informed by multiple perspectives.

CCEEB states that, through its Climate Change Project, it assists the state in the development of efficient and effective regulatory structures to reduce GHG emissions in California.
California Energy and Infrastructure Labor-Management Cooperation Trust (LMCT)

The California Energy and Infrastructure Labor-Management Cooperation Trust (LMCT) states that it assists workers and employers in solving problems of mutual concern not susceptible to resolution within the collective bargaining process and it studies and explores ways of eliminating potential problems, which reduce the competitiveness and inhibit the economic development of the oil refining and producing industry in California.
LCMT collaborates to balance climate policies while reducing the potential negative impacts on workers, families, consumers and the economy.

Canadian Fuels Association

The Canadian Fuels Association (CFA) represents Canada's transportation fuel industry. CFA states that its mission is to drive Canada forward by promoting policies that improve industry environmental performance, protect industry competitiveness, strengthen Canada's critical energy infrastructure, and ensure dependable, safe, and environmentally responsible transportation energy is accessible to all Canadians.
The CFA states that since 2000, its members have invested over $15 billion to improve the environmental performance of fuels and fuel refineries. It also states that they have reduced refinery greenhouse gas emissions, improved energy efficiency and reduced water usage.
Clean Fuels Alliance America

Clean Fuels Alliance America states that biodiesel, renewable diesel and renewable jet fuel will be recognized as mainstream low-carbon fuel options with superior performance and emission characteristics. In on road, off road, air transportation, electricity generation and home heating applications, use will exceed six billion gallons by 2030, avoiding over 50 million metric tons of CO2 equivalent greenhouse gas emissions annually. With advancements in feedstock, use will reach 15 billion gallons by 2050.

The association's plan recognizes there is no logical path to zero carbon without growing volumes of low-carbon transportation fuels like biodiesel and renewable diesel. Clean Fuels Alliance America represents more than 100 companies in nearly all 50 states, varying from Fortune 100 companies to small, family-owned producers.

*Valero, through its consolidated joint venture, Diamond Green Diesel Holdings LLC (DGD), is the largest renewable diesel producer in North America. DGD is the member of Clean Fuels Alliance America.
Domestic Energy Producers Alliance

The Domestic Energy Producers Alliance (DEPA) describes itself as a nationwide collaboration of 39 coalition associations – from California to West Virginia, Texas to Montana – representing individuals and companies engaged in domestic onshore oil and natural gas exploration and production (E&P). DEPA states that it believes in seeking common ground, and in common-sense solutions to the challenges that face its businesses, including the relationship with the federal legislative and executive branches of government.
DEPA states that it collaborates with other trade associations, including the Energy ESG Council, which aims to objectively integrate all material stakeholder perspectives around ESG attributes deemed material.
While Valero is not an oil and gas exploration and production company, to the extent Valero can, it looks for opportunities to promote dialogue across the liquid fuels industry, including on policies and initiatives that could lower the carbon intensity of conventional and low-carbon fuels.
Fuels Industry UK Limited

Fuels Industry UK, which changed its name from the United Kingdom Petroleum Industry Association (UKPIA) in August 2023 is a trade association that brings together companies involved in refining, renewable fuel production, terminal operations and filling stations. Its members contribute significantly to the UK's extensive and resilient fuel supply chain today and are preparing for the future by planning and investing in projects that reduce emissions. Fuels Industry UK and its members are committed to taking a leadership role in shaping a flexible and resilient fuels future for UK industry.
Fuels Industry UK believes the U.K.'s downstream oil sector can be a core contributor to tackling the U.K.'s emission targets with its members at the heart of those efforts.
Fuels Industry UK describes that along with the downstream oil industry, they work with government, regulators and other stakeholders in order to identify the best ways to achieve emissions targets, including:
• Identifying and implementing the lowest cost carbon reduction options
• Improving energy efficiency
• Investigating and developing new low-carbon fuels and technologies and the policies to implement them
• Raising awareness of the importance of carbon reduction
• Guiding society so that behavior is influenced and changed
• Learning best practice from other countries
• Working with other countries to develop international plans to reduce greenhouse gas emissions and to introduce new fuels and technologies
Louisiana Mid-Continent Oil and Gas Association

The Louisiana Mid-Continent Oil & Gas Association (LMOGA), founded in 1923, describes itself as a trade association exclusively representing all sectors of the oil and gas industry operating in Louisiana and the Gulf of Mexico. LMOGA states that it serves exploration and production, refining, transportation, marketing, and mid-stream companies as well as other firms in the fields of law, engineering, environment, financing, and government relations.
LMOGA's mission is to promote and represent the oil and gas industry operating in Louisiana and the Gulf of Mexico by extending the representation of its members to the Louisiana Legislature, state and federal regulatory agencies, the Louisiana congressional delegation, the media, and the general public.
LMOGA states that its members are making significant investments in new technologies for a cleaner future and the production of lower-carbon fuels, and have been instrumental in reducing statewide emissions.
LMOGA states that its members are making significant investments in new technologies for a cleaner future and the production of lower-carbon fuels, and have been instrumental in reducing statewide emissions.
LMOGA states the industry has invested billions in GHG emissions mitigation strategies, such as CCS, which supports their goals of meeting the world's growing need of energy while also advancing a lower-carbon future.
Texas Oil and Gas Association

The Texas Oil and Gas Association (TXOGA) is a statewide trade association representing every facet of the Texas oil and gas industry including small independents and major producers. Collectively, the membership of TXOGA produces approximately 90 percent of Texas' crude oil and natural gas and operates the vast majority of the state's refineries and pipelines. The mission of TXOGA is to promote a robust oil and natural gas industry and to advocate for sound, science-based policies and free-market principles. TXOGA members enrich human lives throughout Texas and the world by providing affordable, reliable energy to consumers. TXOGA members prioritize collaboration in developing innovative solutions and breakthrough technologies to meet the energy demands of today and the future.
As the world seeks to address climate change, TXOGA members continue to have an essential role to play by delivering meaningful greenhouse gas emission reductions and innovative solutions. To further achieve climate progress, greenhouse gas emission-reduction efforts are a global responsibility with participation from all sectors and industries. TXOGA supports public policy that recognizes oil and natural gas are indispensable, facilitates meaningful greenhouse gas (GHG) emissions reductions, and balances economic, environmental, energy and national security needs while promoting innovation. TXOGA seeks to be part of the solution to climate change.
Western States Petroleum Association (WSPA)

Western States Petroleum Association (WSPA) describes itself as representing companies that account for the bulk of the petroleum exploration, production, refining, transportation and marketing in Arizona, California, Nevada, Oregon and Washington. WSPA notes that it works with government leaders, regulators, the media and the public to share information and create an inclusive dialogue about their shared energy future.
WSPA's carbon policy states that the way the world produces and consumes energy is evolving; and that its members are on the cutting edge of those changes, investing in and developing the diverse energy sources and technologies of the future.
WSPA states that if a state is going to pursue climate policy, market-based approaches can help balance the need to achieve greenhouse gas emission targets while reducing the economic impact on families, consumers, and the economy.

Engagement/Advocacy Report