St James's Place PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	St James’s Place provides a reasonable but still partial picture of its climate-related public-policy engagement. It names two identifiable policy frameworks it has lobbied on—the UK Sustainability Disclosure Requirements (SDR) being developed by the Financial Conduct Authority and implementation of the Task Force on Climate-related Financial Disclosures (TCFD)—and indicates that these are the focus of its climate policy work. The firm also sets out the channels it uses, stating that it submits “consultation responses” and holds “individual meetings” with targets such as the FCA and other regulators, showing some clarity on both method and audience. However, its description of intended policy outcomes remains high-level: it says it wants to “help shape policy to enable strategic commercial objectives and societal good,” support “climate-related targets” and align with the Paris Agreement, but it does not spell out the specific legislative amendments, thresholds or timelines it is advocating. Taken together, the company demonstrates a moderate degree of transparency—clear on the main policies addressed and on the basic engagement tools, yet still vague about the concrete changes it seeks to bring about.	2

Lobbying Governance

Overall Assessment	Comment	Score
None	St James’s Place PLC outlines extensive climate-related governance structures, noting that “The plc Board sets the strategic direction in relation to our climate approach” and that “The Investment Committee supports management to provide oversight of our responsible investment strategy.” It also describes how it “conduct[s] an annual assessment which feeds into our Value Assessment Statement and Investment Committee” and that “the Responsible Investment team…are responsible for implementing our responsible investment frameworks.” However, while these disclosures reflect a robust general climate and responsible investment framework, we found no evidence of any internal processes, oversight bodies, or monitoring procedures specifically governing the company’s direct or indirect lobbying activities or ensuring alignment of lobbying with its climate strategy.	0