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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Prudential Financial Inc. provides comprehensive and highly specific disclosure of its climate-policy lobbying. It names three distinct regulatory proposals on which it intervened—the Securities and Exchange Commission’s proposed “rules on climate-related disclosures,” the SEC’s draft “ESG disclosures for Investment Advisers and Funds,” and the International Sustainability Standards Board’s “proposed Disclosure Standards”—and identifies each as focused on climate-related reporting in the United States or, in the ISSB case, globally. For each proposal the company explains the mechanism used—a formal written response to the regulator’s public consultation—and clearly identifies its lobbying targets, namely the SEC and the ISSB. Prudential also sets out the outcomes it sought, advocating for items such as “a materiality threshold for climate-related financial disclosures, Scope 3 disclosure requirements, additional guidance on transition plans, corporate governance disclosures, and requirements related to internal carbon price and scenario analysis,” urging the SEC to distinguish between ESG-integration and ESG-focused strategies and to mandate “detailed proxy voting and engagement activity information,” and recommending “industry-specific standards” and “testing of climate resilience by investee companies” in the ISSB framework. By articulating the policies addressed, the specific channels and counterparties engaged, and the precise changes it wants incorporated, the company demonstrates a high level of transparency about its climate lobbying efforts.
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4
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| Overall Assessment |
Comment |
Score |
| Moderate |
Prudential Financial discloses a formal oversight structure for its policy advocacy, noting that "The Corporate Governance and Business Ethics Committee oversees the Board’s corporate governance procedures and practices, including…its political contributions and lobbying expenses policy" and "reviews and approves an annual report on political activities, contributions and lobbying expenses." The same Committee’s remit explicitly extends to "its strategy and reputation policy regarding environmental, social and governance issues, including environmental stewardship, sustainability, climate," indicating that climate considerations are included when it "monitors and evaluates the Company’s ongoing political strategy." This annual review and board-level sign-off represent a concrete mechanism to monitor lobbying and provide guidance, while the company also "disclose[s] semiannual information on dues, assessments and contributions of $10,000 or more to trade associations and tax-exempt advocacy groups," showing that indirect lobbying channels are at least tracked and reported. However, we found no evidence of a dedicated process that tests whether those lobbying positions are aligned with the company’s climate strategy, nor any commitment to conduct engagement "in line with the goals of the Paris Agreement," which the company states it "do[es] not plan to have". The disclosure therefore demonstrates a named oversight body and a recurring review of lobbying activities, but lacks detail on how climate-specific alignment is assessed or how misalignments with trade associations are addressed, limiting the overall strength of its lobbying governance.
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2
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