Oppenheimer Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Oppenheimer Holdings Inc’s disclosures detail that “the Compliance Committee is composed of the seven independent directors, meets quarterly” and that it is charged with overseeing “the Company’s compliance function, including the Company’s compliance management system and the Company’s compliance with applicable laws, rules and regulations.” The committee reviews and approves revisions to foundational policies, including the “Code of Conduct” and “Global Anti-Money Laundering Policy,” and ensures independence by a process through which “the Chief Compliance Officer has direct access to the chairperson of the Compliance Committee” and “reports to the Compliance Committee outside the presence of management.” The committee also receives “periodic reports on regulatory inquiries and findings” and directs “any annual or periodic independent compliance or AML audit.” While these disclosures indicate a thorough compliance governance framework, we found no evidence of any governance process specific to lobbying activities, nor any oversight or alignment of direct or indirect lobbying with the company’s climate or policy objectives. View Sources	E

Overall Assessment

Analysis

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None

Oppenheimer Holdings Inc’s disclosures detail that “the Compliance Committee is composed of the seven independent directors, meets quarterly” and that it is charged with overseeing “the Company’s compliance function, including the Company’s compliance management system and the Company’s compliance with applicable laws, rules and regulations.” The committee reviews and approves revisions to foundational policies, including the “Code of Conduct” and “Global Anti-Money Laundering Policy,” and ensures independence by a process through which “the Chief Compliance Officer has direct access to the chairperson of the Compliance Committee” and “reports to the Compliance Committee outside the presence of management.” The committee also receives “periodic reports on regulatory inquiries and findings” and directs “any annual or periodic independent compliance or AML audit.” While these disclosures indicate a thorough compliance governance framework, we found no evidence of any governance process specific to lobbying activities, nor any oversight or alignment of direct or indirect lobbying with the company’s climate or policy objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E