United Airlines Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	United Airlines discloses extensive and precise information on every facet of its climate-policy lobbying. It names the exact measures it targets, including the SAF production tax credit in the Inflation Reduction Act of 2022, state-level “Illinois SAF Tax Credits” and Colorado clean-fuel incentives, the Biden Administration’s SAF Grand Challenge, and the international “Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).” The company explains how it influences these measures, noting that it “engages directly and indirectly with policymakers at the federal, state, and local levels,” leads an 80-member SAF Coalition, conducts “policy workshops with governors, members of Congress and the Administration,” collaborates with the Secretary of Transportation, the FAA and its Air Traffic Organization, and works with ICAO delegates while trialling CORSIA-eligible fuel reporting with the FAA. United is equally explicit about the results it is pursuing, seeking to “create an economic incentive for increased SAF production within the U.S.” through production tax credits, lower the cost of SAF via state credits, set a CORSIA baseline “closer to 100 % of 2019 emissions” to channel funds toward SAF rather than offsets, and deliver the Grand Challenge goal of 3 billion gallons of SAF by 2030. By identifying the specific laws, the engagement channels and targets, and the concrete policy changes it advocates, the company demonstrates a comprehensive level of transparency around its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	United Airlines appears to maintain a moderate governance framework for its lobbying activities, with oversight from the Public Responsibility Committee of the UAL Board and senior executives. It states that public engagement on climate issues is coordinated through our International Regulatory Affairs and Government Affairs departments to ensure consistency across business divisions and geographies, and that our environmental programs and policies, including environmental sustainability, are overseen by Uniteds President and the Executive Vice President of Government Affairs and Global Public Policy, with the Managing Director of Global Environmental Affairs and Sustainability reporting into government affairs to promote alignment with its climate strategy. The companys Code of Ethics and Business Conduct and related lobbying policy, which is publicly available on our website, are reviewed at least annually by the Public Responsibility Committee, and the Executive Vice President of Government Affairs and Global Public Policy reports regularly to the UAL Board on policy advocacy and lobbying expenditures. However, United does not disclose a specific climate-lobbying alignment process for its indirect lobbying through trade associations, nor does it publish an in-depth audit or third-party review of its climate-related lobbying activities.	2