Direct Lobbying Transparency
| Overall Assessment | Comment | Score |
|---|---|---|
| Moderate | Healthpeak Properties is relatively transparent in explaining that it does not conduct direct climate-policy lobbying. The company states, “We generally do not use company funds for lobbying activities” and adds that it “does not make political contributions or directly participate in lobbying efforts,” thereby clarifying that it has no direct engagements with specific climate legislation. It discloses its indirect approach through trade associations, detailing payments of $162,657 to Nareit and identifying that only 0.07 % of those dues were used for political spending; this demonstrates openness about the mechanism it does fund (membership in Nareit and participation on the Real Estate Sustainability Council) even though it does not identify particular government targets or describe any direct actions such as meetings or letters. By explicitly stating that it does not seek particular legislative outcomes and only aligns generally with Nareit’s support for “flexible, principles-based SEC climate change disclosure rules” and energy-efficiency measures, the company makes clear that no specific policy changes are being pursued. Altogether, Healthpeak provides a candid account of its limited, association-based engagement while confirming the absence of direct lobbying activity, but it offers little detail on individual policies, the precise techniques Nareit may employ, or concrete policy objectives, leaving its public disclosure moderate rather than extensive. | 2 |