Moody's Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Moody's Corporation has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly identified specific climate policies it has engaged with, such as responding to the SEC's Request for Comment on Climate Disclosure, the IFRS Foundation consultation paper on sustainability reporting, and the European Financial Reporting Advisory Group on a European sustainability reporting standard. Additionally, Moody's has engaged with the European Commission on ESG ratings and ESG in credit ratings, and the European Central Bank's draft 'Guide on climate-related and environmental risks.' These disclosures provide clarity on the specific policies and regulations targeted. Moody's has also been transparent about its lobbying mechanisms, detailing its direct and indirect efforts, such as submitting formal comment letters to the SEC, engaging with the IFRS Foundation and European Commission through consultations, and providing comments to the UK Department for Work & Pensions and the European Central Bank. The company has identified specific policymaking targets, including the SEC, the European Commission, and the IFRS Foundation, demonstrating clarity in its lobbying efforts. Furthermore, Moody's has been explicit about the outcomes it seeks, such as supporting the SEC's climate disclosure rule with recommendations for a principles-based approach, additional preparation time, and broader safe harbor protections for Scope 3 emissions reporting. It has also expressed support for the EU Green Bond Standard and proposed technical clarifications to enhance global reporting standards. These detailed disclosures illustrate Moody's commitment to transparency and alignment with its climate objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Moody's has demonstrated strong governance in its climate lobbying processes by disclosing a defined governance structure and responsible parties. The evidence highlights that "Moody's Government Public and Regulatory Affairs team, which is part of Moody's Global Corporate Affairs team, manages Moody's political and public policy activities, including direct engagement with government officials and indirect engagement through trade associations and other policy influencers." This indicates a clear structure for managing lobbying activities. Furthermore, the head of Moody's Global Corporate Affairs "is a member of Moody's Executive Leadership Team with a direct reporting line to the President and CEO," showcasing accountability and oversight at the highest level. Additionally, Moody's has established the ESG Outreach and Research (O&R) function, which "convenes quarterly ESG Content Councils and, together with regular working groups on priority areas, coordinates strategic ESG partnerships with membership organizations and bodies, and speaking and policy engagements on ESG topics." This ensures alignment of public statements, research collaborations, and policy engagements with Moody's corporate climate change strategy. While the evidence does not mention a detailed lobbying audit or review, the robust details on governance processes and responsible parties indicate strong governance.	3