Halliburton Co

Halliburton maintains formal oversight over its political engagement but provides limited detail on climate-lobbying alignment and management processes. It notes that "The Nominating and Corporate Governance Committee is responsible for oversight of political expenditures, payments to trade associations, and lobbying activity," and it issues "Updates from management, on an annual basis, regarding any political contributions made by the Company... including any expenditures on lobbyists and political action committees, and any contributions to U.S. trade organizations." The company has published its "Halliburton Policies for Political Engagement" report on its website and affirms it has a "public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement." Nonetheless, we found no evidence of a formal process for reviewing or managing the alignment of direct or indirect climate-related lobbying, such as board sign-off on specific climate-lobbying plans, trade-association alignment reviews, or criteria for assessing associations whose positions may conflict with its climate commitments.