Assessment methodology and results

Assessment methodology

For many years, ExxonMobil has worked to align the advocacy positions of trade associations with the company’s climate lobbying principles. Due in part to our efforts, several trade associations we have had leadership positions in, such as the American Petroleum Institute and U.S. Chamber of Commerce, have taken positions more closely aligned with our views on the need to address both energy security and climate change. Where we have not been able to make progress, and when an organization is no longer a constructive participant in the development and advancement of effective climate policy, we have withdrawn our membership. This was the case with the American Legislative Exchange Council (ALEC) in 2018. ExxonMobil also terminated its membership in the Independent Petroleum Association of America in 2022 due to misalignment on climate priorities and other policy considerations.

In the preparation of this report, ExxonMobil has:

• Undertaken a global review of trade association memberships.
• Identified those organizations that are active and influential in the discussions and development of climate policy.
• Reviewed the climate-related statements and positions of those trade associations.
• Assessed their policy positions and advocacy actions as aligned, partially aligned, or misaligned with ensuring energy security and helping society achieve its ambition for a net-zero future.

Recognizing that most, if not all, of the organizations acknowledge the importance of energy security, this assessment specifically focused on their positions on climate. We reviewed and evaluated the following factors:

• Their publicly stated policy positions to determine if they had acknowledged the risks of climate change and expressed support for the goals of the Paris Agreement (as ExxonMobil has), if they were silent on the topic, or if they failed to engage constructively in the development of climate policy.
• The statements and policy principles of each organization, to determine their positions related to limiting average global warming to below 2 degrees Celsius.
• Their principles and policy positions for public support to incentivize emission reductions.
• Their advocacy actions on specific climate policy proposals (e.g., methane regulation, low carbon fuel standards), as well as internal discussions and deliberations amongst their membership on current and prospective policy positions.

For those organizations assessed as partially aligned or misaligned, ExxonMobil has:

• Identified specific areas of partial/misalignment.
• Constructively engaged with each organization to fully understand basis and rationale for area(s) of misalignment, with a view to enhancing alignment.
• Ensured ExxonMobil’s position is understood by the organization if/when misaligned positions are adopted.
• Maintained active engagement to identify aligned advocacy and policy development opportunities.

Going forward, ExxonMobil will:

• Monitor internal developments and external statements to assess commitment to constructive engagement.
• Annually review and publicly report alignment classifications.
• Disclose when an organization is no longer determined a constructive participant in climate policy development and the resulting action taken.

We recognize that there are many different potential pathways that society could take to achieve greater energy security and reach its net zero goals. No single transition pathway, its success, or rate and pace, can be reasonably predicted, given the wide range of uncertainties. Key unknowns include yet-to-be-developed government policies, market conditions, and advances in technology that may influence the cost, pace, and potential availability of certain pathways.

In evaluating alignment, we look at how efforts can enable emission reductions that contribute to the overall ambition, not how they promote a single transition scenario or pathway.

Criteria for inclusion

Of the hundreds of industry and trade associations around the globe of which ExxonMobil and its affiliates/subsidiaries are members, our assessment determined that less than 5% of these organizations are active on climate-related policy.

While the overwhelming majority of our memberships are focused on non-climate related work, our analysis identified 65 organizations that are active and potentially influential in the discussion and development of climate policy in 2023.

It is our expectation that each of these organizations are constructive participants in the discussion and development of climate policy that addresses the need for energy security and helps society reduce greenhouse gas emissions.

Of the 65 organizations assessed as being potentially active and influential in the climate policy space, we found 61 aligned with supporting policies that will help society achieve its ambition for a net-zero future and three organizations are partially aligned. The table below provides a summary of the assessment results:

American Fuel and Petrochemical Manufacturers (AFPM)

Membership of relevant board/executive committees: Executive Committee; Board of Directors; Climate Change Legal Taskforce; Climate Work Group; Environment Committee; Federal and State Government Relations Committee; Issues Committee; Legal Committee; Safety and Health Committee.

Summary of assessment

ExxonMobil representatives worked with AFPM in 2023 to strengthen its support for society’s ambition to achieve a net-zero future and to advocate in support of policies to reduce greenhouse gas emissions.

Throughout 2023, AFPM engaged in constructive efforts, aligned with ExxonMobil’s climate priorities, to encourage a holistic federal transportation policy for fuels and vehicles. 

Moreover, AFPM engaged in public advocacy, both regulatory and legislative, in support of lower-carbon technologies such as CCS and hydrogen, articulating the important role they are expected to play in decarbonizing the transportation, refining, and petrochemical sectors.

In 2024, we worked with AFPM to progress more comprehensive and solutions-oriented approaches to climate policy, including the development of a more robust climate policy framework.

We continue to value AFPM’s voice in the ongoing development of policies important to the refining and petrochemical sectors and note particularly its constructive engagement in 2023 in support of a potential global treaty on plastics.

Ultimately, however, AFPM’s willingness to advocate constructively in support of emissions reductions policies including well-designed, product-level carbon intensity standards, such as a federal low carbon fuel standard, will be determinative in our ongoing evaluation of membership.

Louisiana Mid-Continent Oil and Gas Association (LMOGA)

Membership of relevant board/executive committees: Board of Directors; Executive Committee; Carbon Committee; Environmental Managers Committee; Legislative Committee.

Summary of assessment

ExxonMobil worked with LMOGA to support the regulation of methane emissions, advancement of carbon capture, utilization and storage (CCUS) technology, and other enabling energy transition policies. LMOGA has taken the lead on CCUS and hydrogen advocacy in Louisiana for industry, helping position Louisiana to achieve Class VI primacy. Additionally, LMOGA led a coalition of industry leaders, landowners and legislators to create a first-time CCUS landowner agreement package of legislation. Beyond these issues, ExxonMobil also appreciates LMOGA’s advocacy on various environmental regulatory issues, such as PM 2.5 regulations and Ozone attainment for EMPs working with the Department of Environmental Quality.  

LMOGA engages in state level advocacy including climate-related state policies. LMOGA has not expressed support for the goals of the Paris Agreement, nor developed policy principles or statements relating to limiting global warming to below 2 degrees Celsius, resulting in partial alignment. We believe there is potential for improved alignment and will continue to seek support for our climate policies as low-carbon investments, such as CCS, ammonia, and hydrogen projects, are now priorities for most of LMOGA’s member companies. The organization exerts limited federal outreach and will continue to advocate for low-carbon technologies and policies as they align with state investment priorities.

We believe by continuing engagement with LMOGA, ExxonMobil is best positioned to assert its climate priorities and influence the organization’s strategic planning efforts related to the energy transition. In 2024, we continued to work with LMOGA toward greater alignment, particularly on state-level climate policies that promote energy security and help society achieve a net-zero future.

Texas Oil and Gas Association (TXOGA)

Membership of relevant board/executive committees: Executive Committee; Board of Directors; Legislative Committee.

Summary of assessment

In alignment with ExxonMobil, TXOGA has supported efforts to reduce methane emissions, regulate the disposal of produced water to reduce volumes and mitigate seismic events, as well as secure property tax abatements for emissions-reduction equipment. In the upcoming session, the organization will support ExxonMobil’s efforts to enact legislation critical to our announced Low Carbon Solutions projects. 

TXOGA has publicly stated that action is required on climate change and has voiced its support for some climate-related policies, such as carbon capture and storage, zero routine flaring and energy efficiency. It has not expressed support for the goals of the Paris Agreement, nor developed policy principles or statements relating to limiting global warming to below 2 degrees Celsius, resulting in partial alignment. TXOGA, which focuses its engagement on state-level advocacy including climate-related policies, has expressed that advocating on global issues may negatively impact its relationships with key state officials and potentially affect its support for other ExxonMobil priority climate-related initiatives, such as carbon capture and storage.

We believe ExxonMobil can advance its policy priorities through continued engagement and shape the organization's public stance on key energy transition issues. In 2024, we continued to work with TXOGA and its member companies to further our climate priorities and develop additional climate-related policy positions and advocacy efforts to help society meet global energy demand and achieve a net-zero future.

American Exploration & Production Council (AXPC)

Membership of relevant board/executive committees: Board of Directors, Executive Committee, Coordinating Subcommittee, Government Relations Committee, Ops Integrity and Wildlife Committee, EHS Committee, ESG Committee, Air & Climate Committee, Water & Waste Committee, Health & Safety Committee, Law Committee

Summary of Assessment - MISALIGNED

On its website and in its publicly available content, AXPC takes high-level positions on climate change that are largely consistent with ExxonMobil’s. On the webpage titled “AXPC Climate Policy and Principles,” AXPC states that, “American oil and gas producers have an irreplaceable role in meeting the challenge of global climate change” and that the organization “supports innovative, collaborative solutions that lower greenhouse gas (GHG) emissions while meeting the world’s growing need for abundant, low-cost, reliable energy.”

However, in its various technical, policy, and strategy committees, AXPC has increasingly diverged from ExxonMobil’s climate principles. AXPC’s 2023 advocacy priorities included methane regulations and development and land access issues. In both areas, AXPC was misaligned with ExxonMobil. AXPC’s approach to methane differs from ExxonMobil’s significantly. On development and land access issues, AXPC’s position has been to repeal as many of this Administration’s regulations as possible, which is inconsistent with ExxonMobil’s more nuanced approach to these issues.

ExxonMobil’s stated approach to lobbying is that “our direct lobbying activities are aligned with limiting average global warming to below 2 degrees Celsius and include strong support for policies that will incentivize carbon emission reductions while providing the energy security the world needs.” This includes our support for federal methane regulations, which we have consistently advocated for as the most effective way to reduce methane emissions at scale. AXPC has taken positions that are inconsistent with ExxonMobil’s approach, including pushing back aggressively on the Biden Administration’s methane regulations.

In 2024, ExxonMobil, through its participation in the various strategy and technical committees, worked to bring AXPC closer in alignment with ExxonMobil climate principles to the greatest extent possible. Although we work with AXPC on a number of issues important to industry beyond climate, we have decided to end our membership in 2025.