Valero Energy Corp

Valero discloses a multi-layered process that actively governs both its own advocacy and its trade-association relationships and makes the results public, indicating comprehensive governance. The company states that its "Policy on Political Contributions, Lobbying and Trade Associations" guides engagement and that the CEO and General Counsel "review and approve recommendations by Valero's government affairs team on political contributions and lobbying activities," while the Board-level Sustainability and Public Policy Committee "receives, at least once annually, a formal report from management on these activities." Oversight of climate aspects is reinforced as the committee is charged with "political issues, including political contributions and lobbying activities," and the General Counsel "has direct reporting duties to the Nominating/Governance and Public Policy Committee." In addition to this structure, Valero publicly releases an "Annual climate lobbying report, including alignment analysis of indirect lobbying through trade associations," noting that it "conducted a review of climate lobbying activities and concluded that certain trade associations with lobbying activities were substantially aligned with, or were in the process of aligning with, Valero's vision of providing affordable and sustainable energy while reducing GHG emissions." The disclosure that the company "found the following trade associations substantially aligned with, or are in the process of being aligned with, our vision" demonstrates an active mechanism for addressing misalignment, and the published report covers indirect lobbying in depth. Direct lobbying is also captured through the Board's recent reviews of "political spending and lobbying," and the full Board "regularly receives... updates on... political, reputational, ESG and sustainability, HSE, cybersecurity and IT, public policy and climate-related risks," showing routine monitoring. While Valero currently lacks a Paris-alignment commitment, the publicly available alignment analysis, explicit policies, and clearly named oversight bodies together signal strong transparency, a defined monitoring cycle, and board-level accountability for ensuring that its climate-related lobbying activities remain aligned with its stated strategy.