Schroders PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Schroders PLC provides an unusually detailed picture of its climate-policy advocacy. It names numerous specific legislative files it has worked on, including the EU Corporate Sustainability Reporting Directive, the “Revision of the Non-Financial Reporting Directive,” the European Commission’s “Action Plan on Sustainable Finance,” MiFID, UCITS and AIFMD sustainability amendments, EU requirements on ESG rating and data providers, the UK FCA’s Sustainability Disclosure Requirements, the US SEC’s climate-disclosure rulemaking (file s7-17-22) and Australia’s Climate-Related Financial Disclosures consultation, among others. The company also lays out the channels through which it lobbies: face-to-face and virtual meetings with MEPs, MPs, European Commission and Council officials and national finance ministries; bilateral engagements in France, Spain and Luxembourg; coordinated public letters and joint policy positions; written submissions to consultations by bodies such as ESMA, the FCA, the SEC and the Australian Government; and public advocacy at UNFCCC COP meetings. These disclosures precisely identify the policymaking targets—e.g., “policy makers in the EU (MEPs, Commission, Council),” the “European Commission’s services,” national governments and regulators in London, Brussels and other capitals—demonstrating full transparency on both mechanism and audience. Finally, Schroders is explicit about the outcomes it seeks: expanding mandatory climate-risk reporting to more companies and into annual management reports, introducing “mandatory disclosure of key risks and indicators,” supporting “legislative initiatives on carbon pricing,” broadening the EU taxonomy to cover transition activities, removing power-of-attorney requirements and blocking rules that hinder shareholder voting, ensuring “good governance” and conflict-free ESG ratings, and preserving competition in the proxy-adviser market. By clearly linking each engagement to a concrete policy change or safeguard it advocates, the firm shows a comprehensive level of transparency across all aspects of its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Schroders PLC has put in place a structured governance framework linking its public policy engagement to its climate objectives by embedding the Public Policy Team within key ESG governance bodies. According to its disclosures, “The ESG Steering Committee is responsible for overseeing the delivery of Schroders’ overall firm-wide sustainability strategy and stewardship programme priorities,” with this committee chaired by the Global Head of Investment and including senior management, ensuring high-level oversight of lobbying alignment. Further, its “ESG Regulatory Steering Committee monitors emergent ESG regulations and determines their high-level impact on our ESG strategy and supporting operations,” receiving input from the Public Policy Team, which “actively engages with relevant regulators, industry trade associations and other sustainability initiative bodies.” Moreover, “These touchpoints ensure coherent messaging and activities, so that our contributions to formal and informal policy consultations are aligned with Schroders' overall perspective on climate change.” We found no evidence of a publicly available audit or third-party review specifically assessing the alignment of its lobbying with its climate-related goals. Nonetheless, this structured committee oversight and regular cross-team coordination indicate strong governance of both direct and indirect lobbying activities in line with the company’s climate change strategy.	3