Vistra Corp

Vistra has established a formal review process to align its indirect lobbying efforts with its climate strategy, committing to "review all its memberships with trade groups, associations, and other third-party organizations" annually "to discern whether their positions are materially inconsistent with Vistra's views" and pledging that if its efforts "to align our positions" within those organizations fail, it "may withdraw from or otherwise disassociate" from the group. This indirect lobbying governance is overseen by a clearly designated leader and accountability forums: the Chief Strategy & Sustainability Officer "directly reporting to the CEO" presents to the Sustainability and Risk Committee of the board "at least quarterly," and the Executive, Commitments, and Risk Committees provide daily oversight of environmental principles. We found no evidence of a separate governance process addressing the company's direct lobbying activities or a distinct audit or report evaluating climate-related lobbying alignment.