S&P Global Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	S&P Global discloses a structured process to keep its policy advocacy in line with its climate ambitions. It states that its Government Affairs & Public Policy function “assists our corporate leaders to develop enterprise and divisional policy positions … while providing background on climate and sustainability related public policy developments” and, through an “internal ESG Policy Working Group, [works] … to identify important issues, develop positions, and ensure that all policy engagement is consistent, including with industry trade associations.” This shows a clear mechanism linking climate policy expertise to both direct and indirect lobbying activities. On indirect lobbying, the company notes that “We monitor all memberships for consistency, transparency and alignment with our core values and policy positions,” and provides a public list of “all significant trade association memberships,” indicating ongoing review of trade-association alignment. For direct engagement, it explains that “we regularly meet with policymakers, regulators, and staff to discuss issues that directly affect our business,” and that the same internal working group vets those engagements for consistency with the firm’s ESG stance. Oversight responsibility is explicitly identified: “The S&P Global Board prioritizes climate and sustainability as core considerations” while committees such as the Nominating and Corporate Governance Committee “review… periodic reports from senior management on the Company’s performance against ESG and sustainability-related goals,” showing board-level review of climate-related advocacy; operationally the Government Affairs team manages the day-to-day process. The company also holds a “public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” However, the disclosures do not describe a formal, published climate-lobbying alignment audit or detail specific actions taken to rectify misalignment with trade bodies, so the depth of monitoring remains unclear. Overall, the presence of a defined internal review mechanism that covers both direct lobbying and trade-association activity, combined with identified board and management oversight, indicates strong but not yet comprehensive governance of climate-related lobbying activities. View Sources	B

Overall Assessment

Analysis

Score

Strong

S&P Global discloses a structured process to keep its policy advocacy in line with its climate ambitions. It states that its Government Affairs & Public Policy function “assists our corporate leaders to develop enterprise and divisional policy positions … while providing background on climate and sustainability related public policy developments” and, through an “internal ESG Policy Working Group, [works] … to identify important issues, develop positions, and ensure that all policy engagement is consistent, including with industry trade associations.” This shows a clear mechanism linking climate policy expertise to both direct and indirect lobbying activities. On indirect lobbying, the company notes that “We monitor all memberships for consistency, transparency and alignment with our core values and policy positions,” and provides a public list of “all significant trade association memberships,” indicating ongoing review of trade-association alignment. For direct engagement, it explains that “we regularly meet with policymakers, regulators, and staff to discuss issues that directly affect our business,” and that the same internal working group vets those engagements for consistency with the firm’s ESG stance. Oversight responsibility is explicitly identified: “The S&P Global Board prioritizes climate and sustainability as core considerations” while committees such as the Nominating and Corporate Governance Committee “review… periodic reports from senior management on the Company’s performance against ESG and sustainability-related goals,” showing board-level review of climate-related advocacy; operationally the Government Affairs team manages the day-to-day process. The company also holds a “public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” However, the disclosures do not describe a formal, published climate-lobbying alignment audit or detail specific actions taken to rectify misalignment with trade bodies, so the depth of monitoring remains unclear. Overall, the presence of a defined internal review mechanism that covers both direct lobbying and trade-association activity, combined with identified board and management oversight, indicates strong but not yet comprehensive governance of climate-related lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	S&P Global provides an extensive and precise picture of its climate-related policy engagement. It names a wide range of specific measures it works on, including the EU Regulation on the Reduction of Methane Emissions, Japan’s Financial Services Agency Code of Conduct for ESG Evaluations and Data Providers, IOSCO’s Sustainable Finance Taskforce recommendations, Indonesia’s CCS/CCUS Regulation No. MEMR 2/2023, the draft German Power Plant Safety Act (KWSG), California Air Resources Board carbon-market rulemakings, New Zealand’s Emissions Trading Scheme settings, and the IFRS Foundation’s creation of the International Sustainability Standards Board, among others. The company also explains how it seeks to influence these policies: it “provided input and engaged” with the ISSB and EFRAG, submitted “detailed technical input in the form of consultation responses” to IOSCO and the IFRS Foundation, holds “meetings and briefings” with policymakers and regulators, participates in trade associations such as AmCham EU and the Institute for International Finance, and contributes to multilateral forums like COP, the OECD Green Investment Financing Forum and the UNEP Inquiry. Targets of these efforts are clearly identified, ranging from the European Commission and CARB to central banks, the SEC Asset Management Advisory Committee and national ministries. Finally, S&P Global states the concrete results it is pursuing: it supports “consistent implementation” of IOSCO’s recommendations to avoid regulatory fragmentation, seeks adoption of a “global set of internationally-recognized sustainability reporting standards,” backs wider use of TCFD disclosure requirements, advocates “pragmatic” methane-rule equivalence to protect security of supply, and calls for specific carbon-market allowance reductions and alignment between California and Washington to meet net-zero goals. Taken together, these detailed disclosures on the policies addressed, the ways and fora in which the company lobbies, and the specific legislative or regulatory outcomes it seeks demonstrate a high level of transparency in S&P Global’s climate-policy lobbying.	A