Capital One Financial Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Capital One provides a moderate level of transparency about its climate-policy lobbying. It discloses the principal policy areas it engages on, notably its effort to “advocate for a national price on carbon” during virtual meetings on Capitol Hill and its work in the 2020 Virginia General Assembly session to preserve or expand “choices and opportunities to procure renewable energy.” The company also explains how it lobbies and who it targets: it describes joining other businesses in virtual advocacy meetings with federal lawmakers, and participating in Ceres’ Virginia Lawmaker Education Day where it met directly with state delegates and senators. Finally, Capital One is clear about what it wants these engagements to achieve—support for a federal carbon-pricing mechanism and legislative changes that widen renewable-energy procurement options in Virginia—aligning these external objectives with its own internal carbon price of $15 per tonne. The disclosures stop short of naming three or more distinct policy initiatives or detailing a wider array of lobbying channels, but they still give investors a coherent picture of the company’s principal climate-related lobbying positions, methods and desired outcomes.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Capital One Financial Corp discloses a formal oversight structure for its political activities; a “Committee of the Board, which is composed entirely of independent directors, oversees the Corporation’s governance policies regarding political activity and expenditures” and this committee “approves on an annual basis the corporation’s contribution criteria, spending guidelines and total corporate expenditure budget” while also “reviewing on an annual basis the Corporation’s political contributions ... and the Corporation’s Government and Policy Affairs Group Annual Report.” Requests for political contributions are “evaluated by the Contributions Committee and approved by the Vice President, Head of Government and Policy Affairs,” and contributions are “reported semi-annually.” However, the company does not disclose any process to align its lobbying efforts—direct or through trade associations—with its broader corporate or climate policy objectives, nor any climate-focused auditing or review mechanisms.	1