TC Energy Corp

TC Energy Corp's governance and oversight processes include a Board-level Governance Committee that "oversees lobbying, political contributions, and corporate memberships" and "receives a report annually that provides information on our lobbying activities, a complete list of our political contributions and a detailed list of our corporate memberships," demonstrating formal structures for monitoring political engagement. The company has increased transparency with the publication of its "Climate-related Lobbying Report" alongside its ESG data, and it confirms that "since the publication of the climate-related lobbying report, there has been no change to our association memberships or alignment assessment," indicating a systematic review of indirect lobbying through trade associations. TC Energy also mandates "annual training and certification" under its Political Contributions and Activities Policy, ensuring that employees and contractors are aware of its advocacy rules. However, while the company stresses its support for "the goals of the Paris Agreement" and outlines its advocacy for policies to "reduce emissions," it does not disclose a specific process for aligning and monitoring its direct lobbying activities against defined climate policy positions, and there is no clear explanation of how its Governance Committee or HSSE Committee assesses climate alignment of direct or indirect lobbying on an ongoing basis. We found no detailed criteria for evaluating or adjusting direct advocacy or guidelines that require climate considerations to inform each engagement, so the governance framework for comprehensive alignment of all climate-related lobbying efforts remains only partially articulated.