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Overall Assessment |
Comment |
Score |
Limited |
U.S. Bancorp provides only limited insight into its climate-related lobbying. It indicates that it has “engag[ed] with policymakers in Congress individually and through trade associations to discuss the Basel 3 ‘endgame’ proposals,” showing that the firm has been active on capital-requirement rules that it believes could discourage renewable-energy financing, but it does not name any specific bill, regulatory docket, or amendment within that broad proposal. The description of its approach—direct contact with members of Congress and indirect engagement via industry associations—identifies one broad mechanism and a general target but offers no detail on the form or frequency of those contacts. Likewise, the company only broadly states a concern that the proposals might “disincentiviz[e] investments in renewable energy,” without explaining what precise changes to the Basel 3 package it is advocating. Overall, the disclosure signals that the bank is involved in climate-relevant policy discussions yet stops short of the detailed policy names, lobbying channels, and concrete outcomes that would indicate fuller transparency.
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1
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Overall Assessment |
Comment |
Score |
Moderate |
U.S. Bancorp discloses a formal process to check that its climate-related advocacy is consistent with company policy, stating that Direct and indirect activities are reviewed and approved by a level of senior management not more than three levels removed from the CEO and that the Environmental Program Manager reviews them within the context of our Environmental and Social Risk Policy, as well as U.S. Bancorp's established environmental strategy. Final decisions are taken in collaboration with the Executive Vice President, Chief Social Responsibility Officer and may be further reviewed and approved by the ESG Committee and Climate Risk Working Group, indicating a structured internal review and sign-off mechanism rather than ad-hoc judgement. Oversight is carried up to board level, as the Public Responsibility Committee reviews public policy matters that impact our companys business activity and oversees our ESG strategy, and receives regular updates from management on the companys ESG strategy and climate-related goals, showing that a named board committee monitors managements external positions. The company also notes that instances of non-adherence or violations of company policy are monitored and may be factored into employee incentive compensation decisions, providing a compliance lever. However, the disclosures do not spell out how trade-association positions are assessed or corrected, nor do they reference any public audit or report of lobbying alignment; the statement that it has No plan to adopt a Paris-Agreement lobbying commitment underscores the absence of a published alignment framework. Overall, the company outlines clear internal procedures and responsible parties for approving both direct and indirect engagement, but it does not publicly evidence an explicit methodology or outcomes for aligning those activities with climate policy goals, particularly in relation to industry associations.
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2
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