S&P Global Inc

## Our Approach

We regularly meet with policymakers, regulators, and staff to discuss issues that directly affect our business. Conversely, staff and policymakers have sought briefings from our analysts and other experts on a variety of topics.

We make limited contributions via the **S&P Global Inc. Political Action Committee (S&P Global PAC)** to the campaigns of candidates for U.S. federal office who align with our business priorities and values. The S&P Global PAC is funded by voluntary contributions from eligible employees, and monthly reports of its receipts and disbursements are filed with the U.S. Federal Election Commission. Our **Political Contributions and Payments Policy** prohibits the use of corporate treasury funds for making direct contributions to candidates or political committees at the state or local level, as well as independent expenditure committees known as "super PACs." The company has not contributed to local or state ballot measures or referendums.

S&P Global is an active participant in several **trade associations**, including the Institute for International Finance and the American Chamber of Commerce to the EU (AmCham EU). A list of all significant trade association memberships is available in the Appendix. We monitor all memberships for consistency, transparency and alignment with our core values and policy positions.

In 2023, we continued to promote transparent capital and commodity markets through **engagement with regional and international bodies**. Key activities included the following:

* Chaired AmCham EU's dedicated Sustainable Finance Task Force, a cross-sectoral forum for advice and engagement with policymakers to support implementation of the EU's Action Plan on Sustainable Finance.
* Continued our partnership with the UN Environment Programme World Conservation Monitoring Centre.
* Contributed thought leadership to the public policy debate to advance the work on the sustainable finance agenda at international forums, such as the World Economic Forum and CERAWeek by S&P Global.
* Engaged with the U.S. Commodity Futures Trading Commission in its effort to develop guidance for voluntary carbon markets.

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## ESG/Sustainability Policy and Disclosure Engagement

S&P Global advocates for **global harmonization and consistency of new regulations** supporting the effective integration of ESG and sustainability in financial markets. Our efforts include providing relevant information and filing public comments to regulators and policymakers around the world. Our internal **ESG Policy and Regulatory Working Group** works with executives and subject matter experts to identify issues, develop positions and ensure that all policy engagement is consistent.

Our internal experts are active participants in **key dialogues and initiatives** including the Task Force on Climate-related Financial Disclosures, the Taskforce on Nature-related Financial Disclosures, the Commodity Futures Trading Commission's Climate-Related Market Risk Subcommittee, and the SEC's Asset Management Advisory Committee.

As a leading provider of sustainability data and analytics solutions, we believe in the importance of establishing globally consistent standards for high-quality, transparent, reliable and comparable ESG and sustainability disclosures by companies. Toward this end, we support the International Financial Reporting Standards (IFRS) Foundation and endorse the work of the International Sustainability Standards Board (ISSB) to develop and maintain a comprehensive global baseline of sustainability-related disclosure standards.

The S&P Global Board prioritizes climate and sustainability as core considerations, driving informed strategic decisions and oversight. The Board of Directors of the Company (the Board) views oversight and effective management of ESG-related risks and opportunities as essential to the Company's ability to execute its strategy and achieve long-term sustainable growth. As such, the full Board receives regular updates on a variety of ESG topics, including sustainability and climate-related matters, as part of its annual, in-depth strategy and risk management sessions, as well as ongoing discussions and committee reports throughout the year. The full Board also receives biannual updates on the Company's ESG and sustainability-related products and offerings. In addition to oversight by the full Board, the Board coordinates with its various Committees to ensure active and ongoing Committee-level oversight of the Company's management of ESG and sustainability-related risks and opportunities across the relevant Committees. The Board's oversight is supported by four committees, as outlined in the table below. [...] The Nominating and Corporate Governance Committee (NCGC) reviews and receives periodic reports from senior management on the Company's performance against ESG and sustainability-related goals and metrics, ESG and sustainability-related programs, products and disclosures and Corporate Responsibility policies and programs, including with respect to environmental and climate matters. The NCGC coordinates with the Board on material ESG issues. [...] The Audit Committee of the Board oversees key business and operational risks of the Company. As such, the Audit Committee is responsible for overseeing and reviewing the Company's Enterprise Risk Management (ERM) framework and process, including its governance, risk management practices and key components to facilitate the identification, measurement, mitigation and reporting of risks. In connection with the Audit Committee's oversight of the Company's ERM framework, the Committee considers and discusses with management risk exposures and mitigation strategies with regard to key risks, including material climate-related issues, such as crisis management for business disruptions from natural disasters and other issues that may be driven by climate change. [...] The Finance Committee oversees the Company's financial risks by reviewing the impact of financial and non-financial risk scenarios on the Company's long-term capital position and overseeing major capital expenditure decisions and transactions, such as acquisitions and divestitures. In connection with these responsibilities, the Finance Committee receives annual updates from Management on the estimated financial impact of nonfinancial risk scenarios. [...] The CLDC considers ESG and sustainability and energy transition-related performance related to the Company's strategic goals when making compensation determinations and approving performance objectives for members of the Company's Executive Committee. By linking compensation to strategic ESG and sustainability and energy transition-related goals, such as sustainability and energy transition-related metrics incorporated into management's balanced scorecard for the annual short-term incentive plan, the CLDC encourages and rewards progress against the Company's sustainability and energy transition-related initiatives.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]S&P Global's Government Affairs & Public Policy function assists our corporate leaders to develop enterprise and divisional policy positions for all our business divisions across all geographies where we operate while providing background on climate and sustainability related public policy developments. 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.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes