Morgan Stanley

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Morgan Stanley provides extensive and specific disclosure about its climate-related lobbying. It identifies the concrete policy frameworks it has engaged on, ranging from the “U.S. Securities and Exchange Commission’s proposed rule to enhance and standardize climate-related disclosures,” the “IFRS Foundation’s draft sustainability reporting standards,” the emerging “EU green bond standard” and related corporate sustainability reporting requirements, through to support for the U.S. “Clean Electricity Payment Program” and the Environmental Protection Agency’s proposed methane rules. The firm also details the avenues it uses to influence those measures, combining direct dialogue—such as engagement with “the Board of Governors of the Federal Reserve regarding climate scenario analysis,” meetings with “U.S. Treasury climate leadership,” participation in a Prudential Regulatory Authority round-table, and membership of the CFTC Climate-related Market Risk Subcommittee—with indirect routes including work via the U.S. Chamber of Commerce Climate Action Task Force, the Business Roundtable, and joint statements coordinated by C2ES and the B Team. Finally, it is explicit about the outcomes it seeks: it “supports science-aligned and market-based policies, including a price on carbon,” advocates a “robust, market-based approach to reducing U.S. emissions,” backs the Clean Electricity Payment Program to decarbonise power generation, and endorses stronger methane regulation as well as harmonised international disclosure standards. By clearly naming the policies, revealing both direct and association-based mechanisms and targets, and articulating specific legislative and regulatory goals, the company demonstrates a comprehensive level of transparency around its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Morgan Stanley maintains a structured oversight framework for its political and lobbying activities, anchored by its Corporate Political Activities Policy Statement, which is “approved by the Governance and Sustainability Committee of the Morgan Stanley Board of Directors (the ‘Board’)” and “reviewed annually by ESRM, senior representatives of the business units, the GSO, and other relevant internal control functions.” The Government Relations Department, “under the oversight of Morgan Stanley’s Chief Legal Officer and Chief Administrative Officer, who is a member of Morgan Stanley’s Operating Committee and reports to the Chief Executive Officer,” manages the identification of legislative and regulatory priorities and both “dialogue with U.S. federal and state government officials” and “expenditures related to such participation.” Indirect lobbying through trade associations is governed by an annual review process, as “principal U.S. trade association memberships as well as the expenditures relating to such memberships are reviewed annually with the Government Relations Department and the Governance and Sustainability Committee of the Board.” While this demonstrates clear mechanisms for governing direct and indirect lobbying and named oversight bodies, we found no evidence of a dedicated process or any climate-specific review to ensure alignment of lobbying activities with Morgan Stanley’s climate-related objectives, nor is there a named individual or committee tasked explicitly with climate lobbying oversight.	2