Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Moderate |
First American's disclosures indicate an emerging governance framework for climate-related lobbying, anchored by oversight from its VP, Corporate Real Estate, but lacking formalized processes for both direct and indirect political advocacy. The company states that "our VP, Corporate Real Estate ... would participate and/or oversee the participation in these organizations" that could influence climate policy, ensuring engagement activities "are consistent with First American's climate change strategy," and notes that "any participation found to be inconsistent with First American's values and strategies would be subject to scrutiny." It also clarifies that "executive management, including the CEO and CFO, oversees First American's climate-related strategy," and that the "Compensation Committee considers ESG issues in determining executive compensation," creating an incentive for alignment. However, First American does not disclose a formal policy or recurring review mechanism specifically for climate lobbying, nor any process for direct lobbying activities, and it acknowledges it "does not currently engage in activities that could impact the climate," with no commitment to align future engagement with the Paris Agreement. Together, these elements suggest some governance foundations but leave significant gaps in policy definition, procedural details, and coverage of both direct and indirect advocacy.
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