Definity Financial Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Definity Financial Corporation provides a highly transparent picture of its climate-related lobbying. The company names multiple concrete policy files it works on, including the federal government’s “National Adaptation Strategy,” the Office of the Superintendent of Financial Institutions’ “Guideline B-15” on climate-risk management, and proposals for “a national flood insurance program for high-risk residential properties.” It also sets out the exact channels it uses and whom it approaches: it “participated in roundtable meetings with various federal Cabinet ministers … along with opposition Members of Parliament,” its President and CEO joined “a meeting … with the federal Minister of Emergency Preparedness,” and it “wrote the Deputy Prime Minister” to express support, in addition to ongoing input through Insurance Bureau of Canada and Canadian Institute of Actuaries working groups. Definity is clear about what it wants to achieve—“timely and ambitious implementation of the National Adaptation Strategy,” establishment of the national flood insurance program, and influence over regulatory guidance such as Guideline B-15 to ensure a “whole-of-society approach” to climate adaptation and resilience—demonstrating consistent, specific policy goals rather than vague aspirations. Taken together, these detailed disclosures on policies, mechanisms, targets, and desired outcomes reflect comprehensive transparency in its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Definity Financial Corp describes that it “has a regulatory and industry affairs function that coordinates its participation in these trade associations” and that this function “ensures that Definity has public policy positions on key climate issues” which representatives then bring to “trade association discussions or to the government(s) directly,” demonstrating a clear mechanism for aligning both indirect and direct lobbying with its climate positions. However, Definity also states “No, and we do not plan to have one in the next two years” regarding a commitment to align engagement with the Paris Agreement, and we found no evidence of a formal review or audit of its lobbying activities against climate goals or of a named individual or committee overseeing this alignment. The disclosure suggests a defined process for policy development and participation but lacks a specific oversight structure or procedures for monitoring and enforcing climate-alignment in its lobbying efforts.	2