American International Group Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	American International Group provides only limited insight into its climate-related lobbying. It acknowledges that it engages with regulators on climate and ESG matters, noting that "Outreach to government officials and regulators at the state, federal and international levels encompasses a broad array of insurance industry issues" and that it "engaged with government and regulatory officials to better understand the evolving policy frameworks regarding climate change." However, it does not name any specific bills, regulations or rule-makings it has tried to influence; its disclosures remain at the level of broad subject areas such as climate-risk governance and disclosure. The company describes a general mechanism of "providing feedback to policymakers" and refers to filing LD-2 lobbying reports and participating in industry associations, yet it offers no detail on concrete actions such as particular meetings, letters, consultations or the identity of the public bodies it approaches. Similarly, the outcomes it pursues are expressed only in general terms—AIG says that climate rules should be "sensible, risk-based and consistent across jurisdictions to avoid a proliferation of competing standards"—without spelling out the specific regulatory changes, targets or amendments it is advocating. Taken together, these disclosures confirm that the firm engages on climate policy but stop short of the specificity needed for transparent understanding of its lobbying objectives, methods and policy focus.	1

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	AIG’s lobbying governance framework includes Board and committee oversight, a formal trade-association review process and public lobbying disclosures, but it lacks a comprehensive audit of its climate lobbying or a detailed alignment procedure for its direct advocacy. The company states that “The Board, through the NCGC, oversees ... our policies, practices and reporting with respect to ... government relations and lobbying,” and that “employees involved in lobbying, advocacy and political activities do so in accordance with the AIG Code of Conduct ... and in accordance with all applicable ... laws, rules and regulations governing such activities.” A Government Affairs team “reviewed a select number of Associations to identify whether there was a misalignment in the climate risk policies and values of AIG,” and for any divergences AIG may “voice concerns and/or request that our dissenting view be formally noted.” The company also affirms that “AIG files quarterly LD2 reports, which publicly disclose all of our U.S. federal lobbying activities.” However, we found no evidence of a dedicated climate-lobbying alignment report or of a documented process for ensuring that AIG’s own direct lobbying efforts align with its climate-change commitments, indicating that while indirect lobbying through associations is actively governed, direct lobbying lacks a clear, systematic alignment mechanism.	2