This scorecard provides a detailed breakdown of InfluenceMap's assessment of Sempra'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 Sempra, 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 Sempra's company profile - is accessible via the buttons on the right hand side of the page.
A summary of Sempra'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 Sempra'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 |
|---|---|
| May 2022 | 0/14 (0%) |
| May 2023 | 2/14 (14%) |
| December 2024 | 3/14 (21%) |
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 Sempra'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)?
Sempra's disclosure of its positions and engagement activities on climate policies is limited to top-line climate statements without reference to specific climate-related policies. As a result, the company appears to have excluded key instances of engagement with specific climate proposals.
For example, in April 2023, Sempra signed a joint letter that advocated for weaker implementation of the Inflation Reduction Act's clean hydrogen tax credit and subsidiary SDG&E submitted joint comments in support of the Department of Energy's proposed energy conservation standards for gas stoves. The company also engaged on the Environmental Protection Agency's methane reporting revisions, submitting October 2023 comments with the Differentiated Gas Coordinating Council.
Enel 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. Enel included its climate advocacy activities, positions, and links to the company’s government consultation responses to specific climate-related policies from 2022-2024 in its 2023 Climate Policy Advocacy report, published April 2024. It also covered a range of regions in its disclosure, including Global, Europe, North & South America, Africa, and the Asia Pacific.
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. It also contains sorting options for most recent, and most relevant.
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)?
Sempra has disclosed a partial list of its industry association memberships, but appears to exclude 3 industry associations which are actively engaged on climate policy, including Eurogas, Hydrogen Council, and the International Gas Union.
The company also does not appear to have disclosed an account of its industry associations' positions and engagement activities. Sempra has therefore excluded key instances of engagement with specific climate-related policies by its industry associations.
For example, Edison Electric Institute submitted February 2024 comments advocating for weaker implementation of the Inflation Reduction Act's clean hydrogen tax credit, and has repeatedly advocated against the ambition of the US Environmental Protection Agency's proposed power plant rules, including in December 2023 comments, November 2023 testimony, and August 2023 comments.
See Appendix A below for details of the company's industry association memberships.
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. Iberdrola published a largely complete and accurate of its industry associations' positions and engagement activities on specific climate-related policies.
Iberdrola and its North American subsidiary Avangrid both disclosed the climate policy engagement activities of their industry associations in their respective industry association climate lobbying reviews.
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 Sempra'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 Sempra'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/or 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?
Sempra has committed to annually reviewing the climate policy engagement activities of its industry associations. It has published three annual reviews to date, in 2022, 2023, and 2024.
Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2024, 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?
Sempra has disclosed limited details on its methodology for assessing alignment. Sempra assessed each industry association’s position against Sempra’s own 'energy transition action plan,’ including its aim to reach net-zero greenhouse gas emissions by 2050. Sempra did not however provide more details on the criteria against which it assessed its industry associations, and how this was applied in practice. As a result, it is unclear whether Sempra has assessed its industry association’s policy positions and engagement activities against the 1.5°C goal of the Paris Agreement.
Sempra did however clearly detail the conditions for an association to be assessed as ‘Aligned’, ‘Partially aligned’ and ‘Misaligned’ in its March 2024 review. Additionally, in its December 2024 mid-cycle review update on associations it found to be partially aligned, it provided explanations behind its findings for all 9 partially aligned associations.
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?
Sempra does not appear to have disclosed a clear and detailed framework for addressing misalignments between its industry associations and policy pathways for limiting warming to 1.5°C.
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)?
Sempra has not undertaken a review of the alignment of its own climate policy engagement activities. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5⁰C goal of the Paris Agreement identified by InfluenceMap’s database.
For example, in July 2024 comments to the California Air Resources Board, Sempra subsidiaries SoCalGas and San Diego Gas & Electric appeared to advocate for modifications to the California cap-and-trade program that would weaken the ambition of the program, and would facilities a slower transition away from fossil gas.
At time of this assessment, Sempra's InfluenceMap organization score was 59%, indicating partial misalignment between the Paris Agreement and the company’s detailed climate policy engagement. Please see Sempra’s profile in the LobbyMap databased for additional details on the company's real-world climate policy engagement activities.
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 in August 2023. 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. The company has not updated its review in 2024.
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?
Sempra has not undertaken a review of the alignment of its own climate policy engagement activities. As such, the company has shown no evidence of action to address cases of misalignment with 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?
Sempra assessed 37 associations in its March 2024 review. It excluded actively engaged associations including the Natural Gas Supply Association, Eurogas, and International Gas Union.
The company identified alignment with 29 associations, partial alignment with 8 (including American Petroleum Institute, CalChamber, and Texas Oil & Gas Association), and misalignment with 0.
The company provided an update to its review in December 2024, in which it identified 1 more association to be partially aligned; Edison Electric Institute.
InfluenceMap analysis indicates that the company has at least 6 memberships to industry associations with active climate policy engagement misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database). It also holds membership to at least 3 industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).
Sempra did not identify misalignment with 3 associations (Natural Gas Supply Association, US Chamber, American Gas Association), and partial misalignment with 2 associations (Eurogas, International Gas Union).
Therefore, the company has not identified key cases of 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 for further details on the company’s industry associations.
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.
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?
Sempra has shown no evidence of action to address cases of misalignment with its industry associations. As such, the company does not appear to have shown evidence of action 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 Sempra'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.
| Industry Association | InfluenceMap Performance Band | InfluenceMap Assessment |
|---|---|---|
| Hydrogen Council | C | Partially Aligned |
| International Gas Union | C- | Partially Aligned |
| Edison Electric Institute | D+ | Partially Aligned |
| Eurogas | D+ | Partially Aligned |
| Clean Hydrogen Future Coalition (CHFC) | D | Misaligned |
| USLNG Association (LNG Allies) | E+ | Misaligned |
| The Transport Project | E+ | Misaligned |
| Asia Natural Gas and Energy Association (ANGEA) | E+ | Misaligned |
| Natural Gas Supply Association (NGSA) | E | Misaligned |
| US Chamber of Commerce | E | Misaligned |
| American Petroleum Institute (API) | E- | Misaligned |
| American Gas Association | F | Misaligned |
| California Chamber of Commerce (CalChamber) | F | Misaligned |
| Texas Oil & Gas Association (TXOGA) | F | Misaligned |
