ExxonMobil spent $129,140,000 from 2010 – 2020 on federal lobbying. This does not include state lobbying expenditures, where disclosure is uneven or absent. And Exxon also lobbies abroad, spending between €3,250,000 – 3,499,999 on lobbying in Europe for 2020. ExxonMobil fails to disclose its third-party payments to trade associations and social welfare organizations, or the amounts used for lobbying, to shareholders. Companies can give unlimited amounts to third party groups that spend millions on lobbying and often undisclosed grassroots activity, and these groups may be spending at least double what’s publicly reported.1 ExxonMobil belongs to the American Petroleum Institute (API), Business Roundtable, Chamber of Commerce and National Association of Manufacturers, which together spent $113,498,000 on lobbying for 2020, and supports social welfare organizations that lobby, like the Consumer Energy Alliance (CEA). CEA has drawn attention for its involvement in grassroots campaigns that sent emails and letters using the names and addresses of people without their knowledge.2 We believe ExxonMobil’s lack of lobbying disclosure presents reputational risks that could harm long-term value creation. For example, ExxonMobil supports the Paris climate agreement, yet API reportedly lobbies behind the scenes to weaken environmental legislation, with a secretly recorded Exxon lobbyist describing API as the industry’s ‘whipping boy’ to direct public and political criticism away from individual companies.3 And the New York Times noted Exxon’s involvement in multiple influence campaigns run by FTI Consulting designed to represent grassroots support.4 Highlighting these risks, Norway’s largest private asset manager Storebrand divested from ExxonMobil citing its lobbying practices, including trade groups.5 Last year, this proposal received majority support from shareholders, including support from Blackrock and Vanguard. We urge ExxonMobil to expand its lobbying disclosure.