American Express Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	American Express discloses a structured process that seeks to keep its policy advocacy, including climate-related matters, aligned with corporate objectives: its "government affairs team coordinates with colleagues across our business to assess the potential impact of public policy issues" and "periodically review and evaluate key public policy issues for our company globally," demonstrating monitoring of direct lobbying. Board-level oversight is explicit, as the company "brief[s] our Board of Directors, through its Nominating, Governance and Public Responsibility Committee, on our process to identify the issues on which we engage" and "reports regularly to the ... Committee regarding its engagement in the public policy arena." For indirect lobbying, the company says it "evaluates its memberships in trade associations to ensure that they serve the long-term interests of the Company" and requests disclosure of how dues are used for political activity, indicating an investigative mechanism for alignment. Climate considerations are incorporated: "American Express has developed processes to align our direct and indirect activities that influence policy with the company’s overall ESG strategy, including the Advance Climate Solutions pillar," and external communications with policymakers are "overseen by the Corporate Affairs and Communications Department" with input from "the Corporate Sustainability and ESG teams" to support this alignment. Compliance controls include "periodic reviews conducted by an outside law firm and internal audit," adding a further layer of accountability. The company does not disclose a standalone climate-lobbying alignment report or a Paris-aligned public lobbying commitment, but the combination of board oversight, defined internal procedures, and attention to both direct and indirect channels indicates strong governance, albeit without the comprehensive public audit that would evidence best-practice disclosure. View Sources	B

Overall Assessment

Analysis

Score

Strong

American Express discloses a structured process that seeks to keep its policy advocacy, including climate-related matters, aligned with corporate objectives: its "government affairs team coordinates with colleagues across our business to assess the potential impact of public policy issues" and "periodically review and evaluate key public policy issues for our company globally," demonstrating monitoring of direct lobbying. Board-level oversight is explicit, as the company "brief[s] our Board of Directors, through its Nominating, Governance and Public Responsibility Committee, on our process to identify the issues on which we engage" and "reports regularly to the ... Committee regarding its engagement in the public policy arena." For indirect lobbying, the company says it "evaluates its memberships in trade associations to ensure that they serve the long-term interests of the Company" and requests disclosure of how dues are used for political activity, indicating an investigative mechanism for alignment. Climate considerations are incorporated: "American Express has developed processes to align our direct and indirect activities that influence policy with the company’s overall ESG strategy, including the Advance Climate Solutions pillar," and external communications with policymakers are "overseen by the Corporate Affairs and Communications Department" with input from "the Corporate Sustainability and ESG teams" to support this alignment. Compliance controls include "periodic reviews conducted by an outside law firm and internal audit," adding a further layer of accountability. The company does not disclose a standalone climate-lobbying alignment report or a Paris-aligned public lobbying commitment, but the combination of board oversight, defined internal procedures, and attention to both direct and indirect channels indicates strong governance, albeit without the comprehensive public audit that would evidence best-practice disclosure.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E