Gibson Energy Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Gibson Energy offers a high level of transparency around its climate-policy engagement. It explicitly lists a wide range of specific measures it has lobbied on, including the Government of Canada’s Clean Fuels Fund, the Canadian Net-Zero Emissions Accountability Act, the Output-Based Pricing System, the Greenhouse Gas Pollution Pricing Act, Environment and Climate Change Canada’s Forward Regulatory Plan 2022-2024, and the federal 2030 Emissions Reduction Plan, clearly identifying each policy and its Canadian jurisdiction. The company also spells out how and with whom it engages. It notes that it "participates in ongoing discussions with the provincial government regarding GHG and air emissions regulations for the midstream sector," that it "engaged with policy makers to discuss our previous application to the Clean Fuels Fund with respect to the potential development of a hydrotreated renewable diesel facility," and that it met with "Environment and Climate Change Canada (ECCC)" on proposed VOC regulations—demonstrating multiple disclosed mechanisms (direct discussions, formal applications, participation through trade associations) and naming the targeted governmental bodies. Finally, Gibson is clear about the outcomes it seeks. It aims to align its internal carbon price with the legislated $170 / t CO₂e rate by 2030, to obtain Clean Fuels Fund financing for its renewable diesel project, and to ensure that new federal regulations "take into account, as far as possible, the unique operational factors" of mid-stream facilities so that policy "balances environmental benefits as well as maintaining competitiveness across geographical boundaries." By tying each engagement to a concrete objective and indicating whether it "supports [the policy] with no exceptions," the company provides a detailed picture of its lobbying goals. Collectively, these disclosures show comprehensive transparency on the policies addressed, the mechanisms used, and the specific outcomes sought.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Gibson Energy Inc. has established a process that leverages its enterprise risk management framework and cross-functional expertise to align direct and indirect policy engagement with its Net Zero by 2050 commitment, but the scope of its oversight is limited and it has not committed publicly to Paris-aligned engagement. As the company explains, “risks associated with climate policy are monitored by several groups and are escalated to Gibson’s management team through our ERM process as required” to ensure that “our management team and Board have visibility on the broader climate policy environment,” and it designates its “Sustainability Supervisor and Director of Supply Chain Management, ESG and Stakeholder Relations” as responsible for “maintaining consistency with our climate strategy and conducting any direct and indirect engagement with government and policy.” The framework relies on “internal expertise of various business units, including … environment and regulatory, tax, legal and commercial,” and the use of “a third-party government relations team to monitor relevant regulation changes and help ensure we are consistent in our approach and messaging.” Although Gibson notes that “we conduct minimal lobbying and policy advocacy,” it asserts a commitment that “our engagement activities are aligned with our climate-related goals and the Paris Agreement ambitions.” However, the company does not disclose a process for assessing or aligning the positions of trade or industry associations, does not publish a dedicated climate-lobbying audit or report, and confirms that it has “no public commitment or position statement to conduct engagement activities in line with the goals of the Paris Agreement” in the foreseeable future, indicating gaps in oversight of indirect lobbying and formal Board or committee review of lobbying alignment.	2