Citizens Financial Group Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Citizens Financial Group offers only limited insight into any climate-related lobbying. Its disclosures focus on internal capacity-building and client outreach, noting that “Training content covers the fundamentals of climate, the energy transition, relevant impacts on clients, Citizens’ enterprise-wide Sustainability & Impact strategy, and how we can support clients through our innovative products and capabilities,” but they do not describe meetings with lawmakers, submissions to consultations, or other mechanisms directed at public-policy decision-makers, nor do they identify any specific governmental targets. The company likewise names no particular climate policies, laws, or regulations it has tried to influence; the only engagement cited is with its own “Oil & Gas portfolio” clients, stating, “In 2023, we made progress by engaging with 34% of clients in our Oil & Gas portfolio, and we are on target to engage the rest in 2024.” Finally, while Citizens declares a broad ambition “to support a sustainable, lower-carbon economy,” it does not articulate concrete legislative objectives or policy changes it seeks. As a result, the disclosure conveys general intent but provides very little detail on actual lobbying activities, mechanisms, or desired policy outcomes.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Citizens Financial Group Inc discloses that ESG matters, including climate change oversight, are delegated to the Chief Risk Officer and Chief Financial Officer, which indicates some level of governance over its engagement activities. The company states that it ensures its direct and indirect activities are consistent with its overall climate change strategy, and it has a public commitment to align engagement activities with the goals of the Paris Agreement. However, the evidence does not provide details on specific processes or mechanisms for monitoring or managing lobbying activities, nor does it describe how alignment with climate goals is enforced or reviewed. Additionally, there is no mention of actions taken to align indirect lobbying through trade associations or industry bodies, nor is there evidence of a detailed lobbying governance framework or audit. This indicates limited governance disclosure regarding lobbying activities, particularly in the context of climate-related lobbying.	1