S&P Global Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	S&P Global Inc has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has explicitly named multiple specific climate-related policies it has engaged with, such as the EU Regulation on the Reduction of Methane Emissions, Indonesia's CCS/CCUS regulation MEMR 2/2023, New Zealand's Emissions Trading Scheme (ETS), and the IFRS Foundation's initiative to create an International Sustainability Standards Board (ISSB). These disclosures provide clear details about the policies and their implications, showcasing transparency in identifying the areas of engagement. Furthermore, S&P Global has disclosed its lobbying mechanisms, including direct engagement with policymakers and regulators, participation in trade associations like AmCham EU, and contributions to international forums such as the World Economic Forum and CERAWeek. It has also provided detailed technical input through consultation responses to entities like the IFRS Foundation and IOSCO, and named specific targets such as CARB, the SEC Asset Management Advisory Committee, and the Financial Stability Board. Additionally, the company has been explicit about the outcomes it seeks, such as promoting transparent capital and commodity markets, supporting globally consistent ESG regulations, advocating for the adoption of TCFD disclosure standards, and aligning California's carbon market with Washington state's cap-and-invest program. These clearly stated goals and measurable targets demonstrate S&P Global's commitment to influencing specific policy outcomes and its alignment with broader climate objectives. This level of detail and clarity illustrates a comprehensive approach to disclosing its climate lobbying efforts and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	S&P Global indicates a strong governance approach to climate lobbying by noting that "Government Affairs works with executives and subject matter experts across the Company, through an internal ESG Policy Working Group, to identify important issues, develop positions, and ensure that all policy engagement is consistent, including with industry trade associations," and by stating it "monitors all memberships for consistency, transparency and alignment with our core values and policy positions." Although the evidence does not provide detailed monitoring mechanisms or name specific individuals with oversight responsibilities, this process demonstrates a concerted effort to align both direct and indirect lobbying with the company's broader policy positions, suggesting robust governance of climate lobbying activities at S&P Global.	3