Atmos Energy Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Atmos Energy Corp demonstrates a moderate level of governance in its lobbying activities, with several mechanisms in place to ensure oversight and transparency. The company states that "Payments of Company funds to any trade association, chamber of commerce or a related organization will be reviewed by a representative of Governmental and Public Affairs," indicating a process for monitoring indirect lobbying. Additionally, it discloses that "on an annual basis, Atmos Energy will disclose on our website, in an appendix to this Policy, the aggregate amount of the portion of trade association dues used for lobbying activities," which reflects a commitment to transparency. The governance of direct lobbying is also addressed, as "Employees who are registered lobbyists on behalf of the Company must also comply with Company procedures for tracking and reporting activities and related expenses." Oversight is further reinforced by the involvement of the Vice President of Governmental and Public Affairs, who must approve contributions, and by annual reporting to the Board of Directors, which includes "a discussion of the Company's state and federal lobbying expenditures, payments to trade associations, chambers of commerce or other tax-exempt organizations that may be using the funds for lobbying or political activities." However, while these measures indicate a structured approach to lobbying governance, the evidence does not explicitly detail how Atmos Energy ensures alignment of its lobbying activities with climate-related goals, nor does it provide information on actions taken to address misalignment in trade associations or industry bodies. The company does not disclose a comprehensive process for monitoring or managing climate-specific lobbying alignment, which limits the strength of its governance framework in this area. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Atmos Energy Corp demonstrates a moderate level of governance in its lobbying activities, with several mechanisms in place to ensure oversight and transparency. The company states that "Payments of Company funds to any trade association, chamber of commerce or a related organization will be reviewed by a representative of Governmental and Public Affairs," indicating a process for monitoring indirect lobbying. Additionally, it discloses that "on an annual basis, Atmos Energy will disclose on our website, in an appendix to this Policy, the aggregate amount of the portion of trade association dues used for lobbying activities," which reflects a commitment to transparency. The governance of direct lobbying is also addressed, as "Employees who are registered lobbyists on behalf of the Company must also comply with Company procedures for tracking and reporting activities and related expenses." Oversight is further reinforced by the involvement of the Vice President of Governmental and Public Affairs, who must approve contributions, and by annual reporting to the Board of Directors, which includes "a discussion of the Company's state and federal lobbying expenditures, payments to trade associations, chambers of commerce or other tax-exempt organizations that may be using the funds for lobbying or political activities." However, while these measures indicate a structured approach to lobbying governance, the evidence does not explicitly detail how Atmos Energy ensures alignment of its lobbying activities with climate-related goals, nor does it provide information on actions taken to address misalignment in trade associations or industry bodies. The company does not disclose a comprehensive process for monitoring or managing climate-specific lobbying alignment, which limits the strength of its governance framework in this area.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Atmos Energy outlines several avenues through which it pursues climate-related advocacy — including the use of contract and registered employee lobbyists at the state level, federal advocacy via the American Gas Association, and internal governance measures such as disclosure compliance and Board reporting — yet stops short of naming the specific legislators, agencies, or bills it targets. It identifies broad policy areas, referencing engagements on “All fuels legislation,” the “Proposal of energy efficiency programs in jurisdictions where they are not currently available,” and “Tighter building envelopes to improve insulation and increase efficiency,” but without citing the particular statutes or regulatory proposals at issue. The company is most forthcoming on the outcomes it endorses, explicitly seeking to allow “customers the ability to select the fuel source for their homes and businesses,” support energy efficiency programs, and mandate tighter envelope standards. While these statements provide clear insights into Atmos Energy’s objectives, the absence of precise policy identifiers and lobbying targets limits the overall transparency of its disclosure.	C