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| Overall Assessment |
Comment |
Score |
| Comprehensive |
T. Rowe Price Group Inc has demonstrated a high level of transparency in its climate lobbying disclosures. The company has provided detailed accounts of its lobbying activities by outlining specific engagement mechanisms—such as direct submissions to regulatory bodies like the US SEC, UK FCA, and US Department of Labor, as well as direct discussions with representatives from the Canadian federal government, Credit Agricole, and Serbian officials—which clearly identify both the methods used and the targets of these efforts. In addition, T. Rowe Price has explicitly named the climate-related policies and legislative frameworks it has engaged with, citing examples such as the Ontario Climate Change Adaptation and Resilience Act, the Corporate Sustainability Reporting Directive (CSRD) requirements, and its advisory submissions on sustainable financial disclosure and regulatory standards. The company also articulates concrete policy outcomes that it seeks to achieve, including ensuring the alignment of federal and provincial adaptation plans, promoting sustainable investing through green bond issuance, incentivizing nature-positive outcomes in forestry, and advocating for electrification of mass transit systems in Ontario. For instance, during its engagement with Credit Agricole it aimed to "report a revenue figure tied to [its subsidiary Credit Agricole Transition & Energies]" and offered "a series of recommendations during the meeting to help bring the bank in line with global best practice." These detailed disclosures illustrate a comprehensive and structured approach to its climate lobbying efforts.
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4
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| Overall Assessment |
Comment |
Score |
| Strong |
T. Rowe Price demonstrates a strong governance process for climate lobbying alignment, supported by structured oversight mechanisms and clear accountability measures. The company has established the ESG Oversight Committee (ESGOC), chaired by the head of ESG Enablement, which oversees ESG activities, including memberships, disclosures, and corporate sustainability policies, and reports to the Investment Management Steering Committee (IMSC) and Enterprise Risk Management Committee (ERMC). The ESGOC adopted new governance practices in 2023 to annually review how direct and indirect ESG advocacy aligns with commitments under the Net Zero Asset Managers initiative (NZAM) and the Principles for Responsible Investment (PRI). For example, "The NZAM alignment assessment will specifically evaluate whether our lobbying activities support achieving global net zero emissions by 2050 or sooner." Additionally, the Legislative and Regulatory Affairs (LRA) team assesses alignment for relevant advocacy projects and escalates nonalignment issues. The Nominating and Corporate Governance Committee (NCGC), composed of independent non-executives, monitors performance objectives and progress against climate-related corporate goals, such as the net zero emissions target, and receives biannual updates from the head of ESG Enablement. Furthermore, T. Rowe Price provides transparency into its trade association memberships and lobbying activities, stating, "For a full list of the corporate memberships that T. Rowe Price maintains with trade associations and to which $25,000 or more in membership fees and/or dues were paid in the past 12 months, please refer to the Policies and Disclosures on Political Activities section on our Policies webpage." While the evidence does not mention a published lobbying audit or detailed study of lobbying governance processes, the described mechanisms and oversight structures indicate a robust governance framework for climate lobbying alignment.
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3
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