Chubb Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Chubb Ltd has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names specific policies it has engaged with, such as the "public-private crop insurance program for farmers within proposed farm legislation" and reforms to the "National Flood Insurance Program (NFIP)." It provides detailed information about its lobbying mechanisms, including direct engagement with legislators and participation in coalitions like the SmarterSafer Coalition, as well as responses to state insurance regulators in jurisdictions such as California, Connecticut, Minnesota, New York, Washington, and Pennsylvania. Chubb also identifies its lobbying targets, such as Congress and the Federal Emergency Management Agency (FEMA), showing clarity in both mechanisms and targets. Furthermore, the company outlines specific outcomes it seeks, including advocating for reforms to the NFIP to "move properties to risk-based rates, coupled with mitigation assistance and affordability measures for low-income property owners," and supporting the expansion of products that encourage conservation practices and sustainable agriculture. These disclosures illustrate Chubb's commitment to transparency in its climate lobbying efforts and objectives. 4
Lobbying Governance
Overall Assessment Comment Score
Strong Chubb demonstrates a strong governance process for climate lobbying alignment, with clear policies and oversight mechanisms in place. The company explicitly states that it "maintains a rigorous process to ensure that its direct and indirect activities to influence policy are consistent with the company's strategy and objectives, including overall climate change strategy," indicating a defined policy for alignment of lobbying activities. Furthermore, Chubb has identified responsible parties for overseeing these activities, including the General Counsel, who "is responsible for monitoring ongoing climate-related activities, reporting periodically to the Nominating and Governance Committee of the Board of Directors on those activities and raising any new climate-related issues which may involve advocacy or specific corporate action to the Committee's attention for review and direction." The Government Affairs department also "coordinates with business units and the executive team on public policy and advocacy strategies" and "represents the company's views by engaging with different organizations, associations and groups," highlighting a structured approach to monitoring and managing lobbying alignment. While the evidence does not indicate a comprehensive lobbying audit or detailed review of alignment across trade associations, the governance structure and monitoring processes described reflect strong governance. 3