Exxon Mobil Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	ExxonMobil provides extensive, policy-specific detail about its climate-related advocacy. It names a wide range of instruments it has engaged on, including federal bills such as “H.R. 1512, the CLEAN Future Act,” “S. 986, the Carbon Capture, Utilization, and Storage Tax Credit Amendments Act of 2021,” provisions of the U.S. “Inflation Reduction Act” (e.g., the 45Q and 45V tax credits), state measures like “California SB 253 and SB 261,” Alaska’s “SB 114,” federal and EU draft methane rules, Canada’s Clean Fuel Regulation, the “Global Methane Pledge,” and the U.S. “National Clean Hydrogen Strategy and Roadmap.” The company also discloses how it lobbies: it files comment letters and applications to the U.S. Environmental Protection Agency, testifies at EPA workshops, submits recommendations to the European Commission, participates in advisory bodies such as the National Petroleum Council, and deploys in-house and contract lobbyists for “face-to-face, virtual, and one-on-one meetings” with identified targets that include the “U.S. House of Representatives, U.S. Senate, White House Office, Department of Energy, Environmental Protection Agency, Bureau of Land Management” and their European counterparts. It supplements direct engagement with indirect channels through trade associations like the American Petroleum Institute and coalitions such as the Climate Leadership Council. Finally, ExxonMobil is explicit about the changes it wants: it urges “a coordinated and transparent economy-wide price on carbon,” seeks “expanded 45V language to incentivize the use of low-carbon-intensity natural gas as a hydrogen feedstock,” calls for “comprehensive, enhanced rules to reduce methane emissions,” and advocates that “funding available under the federal carbon capture and storage tax credit should be expanded.” It has even offered its own “Model Regulatory Framework” for methane control and supports extending the IRA’s hydrogen credit from 10 to 20 years. By naming concrete policies, describing the exact channels and decision-makers it targets, and stating clear legislative or regulatory outcomes, the company demonstrates a comprehensive level of transparency around its climate-policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Exxon Mobil discloses a detailed governance architecture that explicitly monitors and evaluates both its own advocacy and the positions of the trade associations it funds. The company explains that it has a rigorous process to determine which public policy issues are of most importance to the company, and that the process spans internal business units and engage[s] with a wide range of third parties both individuals and organizations to ensure external perspectives are considered. Oversight is clearly assigned: ExxonMobils Vice President for Public and Government Affairs, who reports directly to the Chief Executive Officer, is responsible for the stewardship of identified key public policy issues, while each year, the Vice President presents the companys political contributions, lobbying activities and lobbying expenditures to the full Board, along with the Boards Environment, Safety and Public Policy Committee, which is comprised entirely of independent directors. Beyond direct lobbying, the company sets out an explicit review mechanism for its memberships: We regularly review our memberships for alignment on climate-related policy issues where misalignment exists, we will work within the organization to achieve alignment; where we fail to see sufficient alignment we may choose to cease membership, and commits that it will annually review and publicly report alignment classifications and disclose when an organization is no longer determined a constructive participant in climate policy development and the resulting action taken. Exxon Mobil publishes a dedicated disclosure that it describes as a climate-lobbying alignment assessment: This report provides additional detail of our direct and indirect climate-related lobbying activities It also provides an assessment of ExxonMobil and its affiliates climate-related lobbying activities in relevant trade associations for calendar year 2023, covering more than 100 organizations and 100% of the lobbying expenses incurred. Together, these statements demonstrate a full cycle of policy-issue identification, board-level sign-off, annual reporting, and corrective action for both direct and indirect lobbying, indicating very strong transparency and accountability. The company does not disclose use of an external auditor for this assessment, but the publicly available, in-depth report and the clearly defined oversight responsibilities constitute a comprehensive governance process managing climate-related lobbying.	4