Moody's Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Moody’s Corporation provides a highly transparent picture of its climate-policy lobbying. It lists multiple identifiable measures it has engaged on, including the U.S. SEC’s proposed climate-disclosure rule, the IFRS Foundation’s sustainability reporting initiative, the European Financial Reporting Advisory Group’s draft sustainability standard, the European Commission’s consultations on ESG ratings and the EU Green Bond Standard, the European Central Bank’s draft Guide on climate-related and environmental risks, and the UK Department for Work & Pensions consultation on climate-risk governance for pension schemes. For each, Moody’s describes concrete engagement channels—for example it "formally submitted a comment letter to the SEC on their climate disclosure rule," "responded to the IFRS Foundation consultation paper on sustainability reporting," and "provided comments" to the European Commission and the ECB—clearly identifying the target institutions and demonstrating both direct comment-letter lobbying and participation in trade associations and multi-stakeholder working groups. The company also sets out the specific changes it seeks, backing global interoperability of reporting frameworks, calling for "a more principles-based approach to the determination of financial statement metrics," requesting "additional time to prepare and file the required information" and "a broader safe harbor protection for the reporting of Scope 3 emissions" in the SEC rule, and advocating that any EU framework for ESG ratings be "fundamentally principles-based and focused on transparency and integrity" to avoid stifling innovation. This combination of clearly named policies, well-explained mechanisms and detailed desired outcomes reflects comprehensive disclosure of Moody’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Moody’s Corp appears to have a relatively strong governance framework for ensuring its lobbying activities align with its climate strategy, with defined oversight, processes, and executive accountability. The company states that its Government Public and Regulatory Affairs team “manages Moody’s political and public policy activities, including direct engagement with government officials and indirect engagement through trade associations,” and notes that the head of this team “is a member of Moody’s Executive Leadership Team with a direct reporting line to the President and CEO,” establishing clear accountability for lobbying efforts. Climate-related engagements are coordinated through the newly established ESG Outreach and Research function, which “convenes quarterly ESG Content Councils” and “coordinates strategic ESG partnerships with membership organizations and bodies, and speaking and policy engagements on ESG topics,” thereby ensuring that public statements and policy engagements are “aligned across the corporation, and with Moody’s corporate climate change strategy.” Moody’s further commits in its Sustainability Report to “advance our efforts by proactively engaging with stakeholders and policy-makers on corporate and industry action” through its participation in the Net Zero Financial Services Provider Alliance. However, we found no evidence of a dedicated climate lobbying audit or publicly available report evaluating alignment, nor an explicit mechanism for systematically reviewing or exiting trade associations whose positions may conflict with the company’s climate policy.	3