Power Corp of Canada

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Power Corporation of Canada offers a highly transparent picture of its climate-policy lobbying. It names multiple, clearly identifiable regulations it has engaged on, including the U.S. SEC’s proposals on “Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social and Governance Investment Practices” and “Investment Company Names,” the Canadian CSA’s proposed National Instrument 51-107 on climate-related disclosure, the U.S. Department of Labour’s rulemaking “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights: RIN 1210-AC03,” and the global ISSB consultation on climate disclosures. The company spells out the mechanisms and targets for these interventions, citing direct letters and consultation responses to the SEC (16 August 2022), the CSA, the U.S. Department of Labour (13 December 2021), and the ISSB, alongside indirect engagement through bodies such as Climate Action 100+ and the Responsible Investment Association. It is equally explicit about the outcomes it is pursuing: recommendations to refine the SEC’s definitions for “Integration Funds” and improve ESG disclosure tables, support for mandatory climate reporting under CSA 51-107, backing the DOL’s effort to “remove barriers to the prudent integration of ESG considerations for ERISA fiduciaries,” and endorsement of the “integration of the TCFD’s recommendations into [SEC] rulemaking,” all of which it states are “aligned with the Paris Agreement.” By detailing the specific policies, the precise channels used, the authorities addressed, and the concrete changes it is advocating, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Power Corporation has established a clear governance framework for its policy engagement by defining roles and review cycles to align its lobbying with its climate strategy. It states that "At Power Corporation, the CSR Lead provides oversight to ensure that direct and indirect activities that influence public policy are consistent with the Corporation’s overall responsible management strategy, including topics that relate to climate change," and underscores this with mandatory annual training on its "Lobbying Policy" as part of the Code of Conduct, which "contains testing to demonstrate understanding" and requires "all of the Corporation’s officers, Directors and employees [to] certify their compliance." The governance approach extends across its businesses, with Lifeco’s Community Relations Department conducting "an annual review of their direct and indirect activities that influence public policy … to ensure relevancy, efficacy and consistency of approach and strategy," and at IGM and Mackenzie, the "IGM Executive Sustainability Committee" and the "Mackenzie Sustainability Committee" providing oversight to "ensure that all direct and indirect public policy activities related to the environment are consistent with their internal policies, strategies and procedures, including IGM’s climate position and commitments, and Mackenzie’s climate action plan." While this demonstrates oversight of both direct and indirect lobbying, the company does not disclose a dedicated climate‐lobbying alignment report or third‐party audit, and we found no evidence of Board‐level review of lobbying alignment.	3