Exelon Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Exelon provides an extensive and detailed picture of its climate-policy lobbying. It names numerous specific measures it engages on, including the federal Infrastructure Investment and Jobs Act and Inflation Reduction Act, the Clean Air Act and CAFÉ standards, regional initiatives to “cap or price carbon (RGGI, NYISO),” state programs such as New York’s Clean Energy Standard and Illinois’ Zero Emissions Standard, and FERC processes such as the “Advanced Notice of Proposed Rulemaking on Regional Transmission Planning,” “FERC Order 1000,” and “FERC Order 2222,” as well as pending congressional legislation on transmission permitting reform. The company also sets out how it lobbies: it references “direct communication with legislators and regulators,” “participation in proceedings at our Public Utility Commissions,” active engagement at FERC, submissions of comments to the U.S. Department of Energy and Department of Transportation, and indirect work through platforms such as the WIRES coalition, the Climate Leadership Council and the Clean Energy Group, thereby identifying both the mechanisms used and the specific targets (FERC, DOE, DOT, state commissions, ISO/RTOs such as PJM and ERCOT). Finally, Exelon is explicit about the outcomes it seeks, advocating for a national carbon-pricing or dividend system, supporting state programs that compensate zero-carbon generation, seeking “design electric markets that can help meet clean energy policy objectives,” calling for modifications to Order 1000 to speed transmission build-out, defending EPA authority to regulate power-plant emissions and vehicle standards, and aiming to “accelerat[e] the connection of renewable and other clean energy resources, improv[e] grid resilience, increas[e] capacity, and enabl[e] electrification.” Together these disclosures demonstrate a high level of transparency across the policies it lobbies, the methods and forums it uses, and the concrete policy changes it is pursuing.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Exelon appears to maintain strong governance around lobbying, including its climate-related engagements, with clear structures for oversight and processes to align policy advocacy with its clean energy strategy. It describes how its Federal Government and Regulatory Affairs and Public Policy team “works closely with the Corporate Strategy, Innovation and Sustainability Department” to ensure that “direct and indirect activities that influence policy are consistent with our overall clean energy and climate change strategy,” and it names its “Senior Vice President and Chief Strategy and Sustainability Officer” as the individual responsible for coordinating the Sustainability Council, which integrates Government and Regulatory Affairs with sustainability priorities. The company also specifies that “internal lobbyists … report to Government Affairs in connection with all Lobbying Activities” and that detailed “pre-approval, contractual, due diligence, and monitoring requirements” govern all external lobbyists and political consultants, with the Chief Compliance & Ethics Officer providing “quarterly reports to the Audit and Risk Committee” and to operating company boards. However, we found no evidence that Exelon has published a dedicated climate-lobbying alignment report or commissioned an external review to evaluate its advocacy against climate targets, and its framework does not articulate a process for assessing the positions of trade associations relative to its climate goals.	3