This scorecard provides a detailed breakdown of InfluenceMap's assessment of Valero Energy'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 Valero Energy, 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 Valero Energy's company profile - is accessible via the buttons on the right hand side of the page.
A summary of Valero Energy'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 Valero Energy'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 |
|---|---|
| 2022 (No Date) | 3/14 (21%) |
| 2024 (No Date) | 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 Valero Energy'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)?
Valero'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. The company's website links to the US federal and state lobbyist registries, which include recent lobbying registrations on key legislation including the US Inflation Reduction Act's (IRA) Clean Fuel Production Credit. However, these disclosures offer limited details of company positions or policy outcomes sought in engagement activities.
As a result, Valero appears to have excluded key instances of engagement with specific climate proposals. For example in June 2024, Valero engaged on the US Corporate Average Fuel Economy (CAFE) Standards, where it challenged the regulation in the US Court of Appeals, and in September 2024 comments to the US Environmental Protection Agency (EPA), it opposed the Advanced Clean Fleets Regulation, advocating for EPA to deny the California Air Resources Board's request for a waiver or preemption for the rule.
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)?
Valero has disclosed a complete list of its industry association memberships. However, the company's disclosure on its industry associations is limited to top-line climate statements without reference to specific climate policies.
Valero has therefore excluded key instances of engagement with specific climate-related policies by its industry associations. For example, in a February 2024 comments, the American Fuel & Petrochemical Manufacturers] (AFPM) advocated against granting a waiver of preemption for CARB's Advanced Clean Cars II policy, opposing electrification of light-duty road transport, and refuting its legal authority to enact the Advanced Clean Cars II rule.
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 Valero Energy'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 Valero Energy'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?
Valero Energy has published a review of industry associations in 2021, 2022 and 2023. It has not yet published its 2024 review.
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?
Valero Energy has not disclosed a clear and detailed methodology for assessing alignment with its industry associations, beyond stating that all associations are aligned with the company’s vision of “providing affordable and sustainable energy while reducing GHG emissions.” Valero Energy has not disclosed what constitutes a finding of alignment or misalignment. As a result, it is unclear if the company has assessed the alignment of its associations against the 1.5°C goal of the Paris Agreement.
In addition, Valero Energy does not provide an explanation of how each evaluation has been made, limiting details to each trade association’s mission and greenhouse gas reduction efforts. The company states that all industry associations are substantially aligned or in the process of being aligned with Valero Energy’s vision, without disclosing which associations fall under each category.
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?
Valero Energy has disclosed a framework to address potential cases of misalignment, including escalation strategies. The company states that it will work with the industry association to express its positions, promote dialogue, and reach compromise on common goals. The company also states it may abstain from supporting an initiative that diverges from its viewpoints.
However, this framework does not include clear deadlines for associations which 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)?
Valero Energy has not assessed the alignment of its direct climate policy engagement activities against the 1.5°C goal of the Paris Agreement. 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.
For example, Valero Energy has historically supported the role of fossil gas in the energy mix, such as in its January 2024 California Voluntary Carbon Markets Disclosure (AB 1305) where the company supported fossil gas in the energy mix on the basis that it is 'low carbon'. The company has also opposed energy policy, for example in February 2024 comments it opposed the California Air Resources Board’s request for a waiver of preemption for the Advanced Clean Cars II policy, opposing a policy to promote the electrification of light-duty road transportation.
At time of this assessment, Valero Energy’s Organization Score metric was 22%, indicating misalignment between the Paris Agreement and the company’s detailed climate policy engagement. Please see Valero’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?
Valero Energy has not published a review of the alignment of its own climate policy engagement activities. The company has therefore 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?
Valero Energy has assessed 12 industry associations in its review. It did not include key industry associations actively engaged on climate policy identified by InfluenceMap, including FuelsEurope, Tennesse Chamber of Commerce and Industry, and Fuels Industry UK.
The company finds all 12 industry associations to be aligned, including the American Fuel and Petrochemical Manufacturers, Western States Petroleum Association, and Texas Oil and Gas Association.
InfluenceMap analysis indicates that the company has at least 4 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), and 2 industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).
As the company found all 12 associations to be aligned, 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 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?
Valero 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 Valero Energy'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 |
|---|---|---|
| Fuels Industry UK (formerly UKPIA) | C | Partially Aligned |
| Canadian Fuels Association | C- | Partially Aligned |
| FuelsEurope | D | Misaligned |
| International Air Transport Association (IATA) | D | Misaligned |
| Western States Petroleum Association (WSPA) | E | Misaligned |
| Tennessee Chamber of Commerce & Industry | E- | Misaligned |
| American Fuel & Petrochemical Manufacturers (AFPM) | E- | Misaligned |
| Texas Oil & Gas Association (TXOGA) | F | Misaligned |
