This scorecard provides a detailed breakdown of InfluenceMap's assessment of ExxonMobil's disclosures on climate policy engagement. This does not include an assessment of the company's real-world climate policy engagement, which can be found on InfluenceMap's online profile of ExxonMobil, accessible via the buttons on the right hand side of the page.
The disclosure assessments are directly integrated into the CA100+ Net Zero Company Benchmark as part of InfluenceMap's Climate Policy Engagement Alignment’ assessment, under two distinct indicators:
In 2023, InfluenceMap’s methodology to assess corporate disclosures on climate policy engagement was formally updated in line with the Global Standard on Responsible Climate Lobbying and stakeholder input. The detailed methodology - as well as additional resources including best practice guidance and ExxonMobil's company profile - is accessible via the buttons on the right hand side of the page.
A summary of ExxonMobil's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
| Indicator | Score |
|---|---|
| Accuracy of Climate Policy Engagement Disclosure | No, does not meet criteria |
| Sub-Indicator | Score |
|---|---|
| Accuracy of Direct Climate Policy Engagement Disclosure | No, does not meet criteria |
| Accuracy of Indirect Climate Policy Engagement Disclosure | No, does not meet criteria |
A summary of ExxonMobil's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
The Review Score (0-100) assesses corporate performance against seven indicators, using the same traffic-light framework. A ‘Green’ scores 2 points, a ‘Yellow’ scores 1 point, and a ‘Red’ scores 0 points. This total is converted into a percentage from 0 to 100, calculated using the total number of points available (14). As such, only certain scores within the 0 to 100 range are possible under this methodology. A Review Score of 100 would indicate that a company has met all of the assessment criteria related to the review process.
| Date of Review | Score |
|---|---|
| April 2022 | 4/14 (29%) |
| January 2024 | 5/14 (36%) |
This is an assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
InfluenceMap utilizes its proprietary database to assess how corporate disclosures on climate policy positions and engagement activities compare to InfluenceMap's independent assessment of the companies' and industry associations' real-world climate policy engagement. In short, it assesses the extent to which the company has disclosed on all climate policy engagement identified by InfluenceMap's database.
The tables below provide: (1) a breakdown of ExxonMobil's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company published an accurate account of its corporate climate policy positions and engagement activities (as compared to InfluenceMap’s database)?
ExxonMobil has published a partial account of its positions and engagement activities on specific climate-related policies but excludes and provides a misleading account on more than 2 items of material evidence of direct climate policy engagement identified by InfluenceMap's database.
ExxonMobil has disclosed its position on, and engagement with, specific climate-related policies, including the US Inflation Reduction Act and the Environmental Protection Agency (EPA)'s methane regulations. However, ExxonMobil does not appear to have disclosed a complete and accurate account of its climate policy engagement.
For example, a 2022 Lobbying Report released in January 2024 stated that the company “lobbied in support of strong methane regulation”, including the EPA methane rule in the US. In contrast, InfluenceMap assessment shows that the company was unsupportive of the proposal. For instance, comments submitted by ExxonMobil to the EPA in January 2022 showed a mixed position on the proposed regulation, supporting some elements of the policy whilst appearing to suggest that more ambitious state-level programs would be of "questionable legality." Other comments submitted by the company in the same month appeared unsupportive of methane leak detection provisions.
The company has also excluded key engagements with specific climate proposals. ExxonMobil appeared unsupportive of CO2 standards in Australia’s National Vehicle Strategy Consultation in October 2022 and did not support US EPA’s emissions standards for LDVs and MDVs in July 2023.
Further, ExxonMobil has not disclosed an account of its 2023 climate policy engagement activities.
Rio Tinto has published a complete and accurate account of its positions and engagement activities on specific climate-related policies, and this is aligned with InfluenceMap's assessment of the company using its LobbyMap database. Rio Tinto discloses links to the company's government consultation responses to specific climate-related policies from 2020-2023, including the Australian Government's Safeguard Mechanism Reforms, Guarantee of Origin Scheme and Technology Investment Roadmap, in addition to New Zealand's Emissions Trading Scheme, and amendments to New Zealand's Climate Change Response Act 2002. Rio Tinto does not appear to have excluded any material evidence of climate policy engagement.
BP partially met the assessment criteria under this indicator, as it excluded material evidence of climate policy engagement. However, BP’s ‘Advocacy Activities’ webpage provides a clear and detailed disclosure of the company’s climate policy engagement, with filters for jurisdiction; date; and topic, including links to relevant consultation responses.
Has the company published an accurate account of the climate policy positions and engagement activities of the industry associations of which it is a member (as compared to InfluenceMap’s database)?
ExxonMobil has published a partial account of its industry associations' positions and engagement activities on specific climate-related policies. However, ExxonMobil excludes more than three items of material evidence of indirect climate policy engagement identified by InfluenceMap's database.
For instance, the American Petroleum Institute opposed the US EPA's GHG emissions standards for HDVs in June 2023 and GHG targets in the proposed US Federal Acquisition Regulation in February 2023. Further, the US Chamber of Commerce advocated for permitting reform in the US to facilitate the build out of fossil fuel infrastructure in May 2023. In addition, ExxonMobil also excludes 3 industry associations which are actively engaged on climate policy including: Asia Natural Gas and Energy Association (ANGEA), the Federation of German Industries (BDI), and the Consumer Energy Alliance.
See Appendix A below for details of the company's industry association memberships.
BHP has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. For example, BHP has disclosed engagement by 7 of its industry associations on Australia's Safeguard Mechanism Reforms, including links to their consultation responses. While BHP has disclosed links to the climate policies and consultations its industry associations have engaged with, it is not clearly referenced within the disclosure and does not provide a detailed description of the positions taken by its industry associations on some of these policies.
Unilever has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. In its March 2024 industry association review, the company attached LobbyMap profile links to each association’s assessment.
This is an assessment of the quality and robustness of a company's processes to identify, report on, and address specific cases of misalignment between its climate policy engagement activities (direct and indirect) and delivering the 1.5°C goal of the Paris Agreement.
The Review Score is split into seven indicators, which fall within one of three categories:
Review Process: Does the company have clear and robust governance processes to regularly assess alignment against the 1.5°C goal of the Paris Agreement, and address potential cases of misalignment?
Review Assessment (Direct - Company): Has the company identified and addressed specific cases of misalignment between its direct - i.e. corporate - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
Review Assessment (Indirect – Industry Associations): Has the company identified and addressed specific cases of misalignment between its indirect – i.e. via industry associations - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
The table below provides an overview of ExxonMobil's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.
| Review Process | Review Assessment (Direct) | Review Assessment (Indirect) |
|---|---|---|
| Monitor & Review | Identify & Assess | Identify & Assess |
| Alignment Assessment Method | Act | Act |
| Framework for Misalignment |
The tables below provide: (1) a breakdown of ExxonMobil's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company established an annual monitoring and review process to ensure that all of its direct and indirect climate policy engagement activities across all geographies are consistent with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels?
ExxonMobil has published two reviews to date: the first in April 2022, in which it assessed its 2021 climate policy engagement activities, and the second in January 2024, in which it assessed its 2022 climate policy engagement activities.
In its 2024 review, the company committed to "Annually review and publicly report alignment classifications" of its industry associations.
Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2023, with detailed updates on misaligned industry associations each year. The company has committed to continue reviewing its memberships on an annual basis. Alternatively, Shell publishes a detailed review of its climate policy engagement every two years, with a detailed update in the interim year.
Has the company disclosed a clear and detailed framework for assessing alignment, including: (1) the criteria it uses to assess whether its climate policy engagement activities (direct or indirect) align with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels; and (2) a clear and detailed explanation behind each evaluation?
ExxonMobil disclosed a clear methodology for assessing alignment with its industry associations. The company assesses alignment against four key areas: the Paris Agreement, limiting average global warming to "well below 2 degrees Celsius", policies to incentivize emissions reductions, and advocacy on specific climate policy proposals. However, ExxonMobil does not provide a clear explanation of what constitutes a finding of alignment, partial alignment, or misalignment in relation to the criteria disclosed.
In addition, it is unclear whether the company has assessed alignment against the 1.5°C goal of the Paris Agreement. ExxonMobil states that it assesses whether an industry association's advocacy is in line with helping society achieve a "net-zero future", and also reviews statements and policy principles to determine positions related to limiting global warming to "well below" 2°C. However, there is insufficient information provided in this methodology or the assessments to explain how this has been applied in practice, and therefore the extent to which the company has assessed alignment with the 1.5°C goal of the Paris Agreement is unclear.
While Exxon has provided explanations behind the evaluations of its 3 partially aligned industry associations and 1 misaligned industry association, the company has not provided explanations for the remaining 52 industry associations that it found to be aligned.
Unilever is the only company to have met the assessment criteria under this indicator. Unilever assessed its industry associations’ climate policy engagement against both its own climate policy positions, and against science-based policy, determined by “what the Intergovernmental Panel on Climate Change (IPCC) has said is needed to keep global warming below 1.5°C”. Unilever states that this assessment does not mean associations should be expected to support every proposed climate law, but that when an association opposes a specific climate policy, it is incumbent on the association to engage constructively with policymakers to help find alternative, viable policy options that would be (at least) equally effective at reducing emissions.
The company also clearly disclosed the criteria for findings of alignment and misalignment with both its own policy positions and science-based policy, and measured the engagement intensity of each association. It also provided clear and detailed explanations behind each evaluation including their detailed policy positions and links to each industry association’s LobbyMap profile.
Has the company established a clear framework to address misalignments between its climate policy engagement activities (direct or indirect) and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, including the escalation strategies it will use and when it will use these escalation strategies?
ExxonMobil disclosed a framework for addressing misalignments with its industry associations in its review, which includes clear escalation strategies. Where a misalignments exists, the company will work towards alignment with the organization. Where the company fails to find alignment across critical issues, or where an organization is not committed to engaging constructively, ExxonMobil may choose to cease membership to this industry association.
However, ExxonMobil has not disclosed clear deadlines for industry associations that do not amend misaligned practices.
Iberdrola has disclosed a clear and detailed framework to address potential misalignments, including escalation strategies and deadlines for industry associations that do not amend misaligned practices. Iberdrola's escalation strategy includes engagement with the industry association, sending a "notification of dissatisfaction", and formal notification that a termination of membership is being assessed. If the association does not provide a clear and credible action plan to address the misalignment within 12 months, Iberdrola will implement one or more of the following actions: make a clear public statement regarding the misalignment, request the industry association refrains from engaging on misaligned issues, and/or suspension or discontinuation of membership.
Has the company identified and reported on the existence of all misalignments between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database (including all of its subsidiaries, business areas, and operational jurisdictions)?
ExxonMobil broadly states in its lobbying report that its “direct lobbying activities are aligned with limiting average global warming to well below 2 degrees Celsius”.
ExxonMobil did not identify any cases of misalignment with its own climate policy engagement. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
In the report, ExxonMobil stated that it “lobbied in support of strong methane regulation”, including the Environmental Protection Agency (EPA) methane rule in the US. However, InfluenceMap assessment shows that the company was unsupportive of the proposal. For instance, comments submitted by ExxonMobil to the EPA in January 2022 showed a mixed position on the proposed regulation, supporting some elements of the policy whilst appearing to suggest that more ambitious state-level programs would be of "questionable legality." Other comments submitted by the company in the same month appeared unsupportive of methane leak detection provisions. The company has also excluded key engagements with specific climate proposals. For example, ExxonMobil appeared unsupportive of CO2 standards in Australia’s National Vehicle Strategy Consultation in October 2022 and did not support US EPA’s emissions standards for light-duty vehicles and medium-duty vehicles in July 2023.
See ExxonMobil’s company profile for more details of the company’s climate policy engagement.
Danone assessed 12 of its own climate policy positions and engagement activities across Europe, the US, and globally. It found all 12 to be aligned. According to InfluenceMap’s database, Danone does not appear to have any material evidence of negative climate policy engagement during the reporting period. As a result, Danone has assessed its climate policy engagement activities in line with InfluenceMap’s findings. It is the only company to have ‘broadly met’ the criteria for this indicator.
Sasol published a detailed review of its direct climate policy engagement. Sasol assessed the alignment of five of its own climate policy positions, including four in South Africa (Climate Change Bill; Carbon Tax; PCC Just Transition Framework; Upstream Oil and Gas Tax Regime Discussion Document) and one in the EU (European Union Delegated Acts). However, Sasol did not identify any cases of misalignment with its own climate policy engagement. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
As a result, no company has shown evidence of identifying cases of misalignment of its direct climate policy engagement and delivering on the 1.5°C goal of the Paris Agreement.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
ExxonMobil has shown no evidence of action to address cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement.
Danone and Unilever are the only companies to have ‘broadly met’ the criteria for this indicator by default. Both companies do not appear to have any material evidence of negative climate policy engagement according to InfluenceMap’s database, and therefore have no cases of misalignment to act upon.
As a result, no company has actively shown evidence of acting to address cases of misalignment between its own direct climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.
Has the company identified and reported on the existence of all misalignments between the climate policy engagement activities of its actively engaged industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
ExxonMobil assessed 56 industry associations in its review. It did not include three associations which are actively engaged on climate policy: the Consumer Energy Alliance, the Asociación Mexicana de Empresas de Hidrocarburos (AMEXHI), and the Japan Chemical Industry Association (JCIA).
Of the 56 associations assessed, ExxonMobil identified 52 cases of alignment, 3 cases of partial alignment (American Fuel and Petrochemical Manufacturers, Louisiana Mid-Continent Oil and Gas Association, Texas Oil and Gas Association) and 1 case of misalignment (Independent Petroleum Association of America).
InfluenceMap analysis indicates that the company has at least 17 memberships to industry associations with climate policy engagement misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database), and 10 memberships to industry associations with climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).
However, the company has not identified key cases of misalignment and partial misalignment between its industry associations and delivering the 1.5°C goal of the Paris Agreement in line with InfluenceMap’s database. See Appendix A below for further details on the company’s industry association memberships.
Unilever assessed 27 industry associations in its review and identified all cases of misalignment and partial misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database. Unilever has membership to 1 misaligned industry association (Tennessee Chamber of Commerce & Industry), and 10 partially aligned associations.
Enel assessed 97 associations in its review and identified all cases of misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database: Confindustria, Spanish Confederation of Business Organizations (CEOE), and Edison Electric Institute - although the company does not disclose additional details of why each industry association is not fully aligned.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between the climate policy engagement activities of its industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
ExxonMobil has shown some evidence of action to address misalignments.
ExxonMobil withdrew its membership to the Independent Petroleum Association for America in 2022, after deeming it to be misaligned.
As for the two partially aligned organizations, the company states that it will continue to work with them to develop their climate-related policy positions and encourage them to support climate-related policies. However, there are limited details on the specific outcomes sought in these engagements, and the company does not address specific misalignments with the associations.
As such, the company has not demonstrated sufficient evidence of action taken to address specific cases of misalignment and partial misalignment with delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
Unilever is the only company to have met investor expectations in this area, showing evidence of action to address all cases of misalignment between its industry associations and delivering the 1.5⁰C goal of the Paris Agreement, as identified by InfluenceMap’s database. In its review, the company included a section for each association titled “Actions (to be) taken” in which it outlined the actions taken or to be taken with the industry association as per its assessment. For example, Unilever stated that it would write to the Tennessee Chamber of Commerce & Industry stating that their positions do not reflect those of Unilever. It also disclosed it would encourage the European Roundtable for Industry to continue to engage constructively on the EU Green Deal and explore how it can revise its position on the EU Emissions Trading System.
Additionally, Unilever stated that for the 12 associations that were deemed “passively aligned” (minimal to non-existent policy engagement), the company will aim to push the associations to become more actively engaged in promoting outcomes and policies that aid in decarbonization.
Yes, meets criteria
Partial, meets some criteria
No, does not meet criteria
The table below provides a ranking of ExxonMobil's industry associations currently covered by InfluenceMap’s database by Performance Band, i.e. a full measure of a company’s climate policy engagement, accounting for both its own engagement and that of its industry associations. Detailed profiles for all industry associations can be explored via the links in the table.
Industry associations are categorized by InfluenceMap as having climate policy engagement that is aligned, partially misaligned or misaligned with delivering the 1.5°C goal of the Paris Agreement by Performance Band:
The ranking table below is updated automatically on a continual basis as: (1) new evidence is collected for the industry associations; (2) new industry associations are added to the company profile; (3) industry associations are removed from the company profile, e.g. if the company leaves the association.
As such, the industry associations and/or scores in the ranking table below may differ from the findings in Identify & Assess (Indirect) above, which was written on the date of assessment. See the top of this page for the date of assessment.
