PNC Financial Services Group Inc/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	PNC Financial Services Group offers a moderate level of transparency on its climate-policy lobbying. It lists a clear set of measures it has engaged on, naming the “SEC climate disclosure rule,” the “Basel Committee Consultation on Disclosure of Climate-Related Financial Risks,” the “California Voluntary Carbon Disclosure Law (AB 1305),” the “California Climate Corporate Data Accountability Act (SB 253),” and the “California Climate-Related Financial Risk Act (SB 261),” giving readers a concrete view of the legislative and regulatory proposals on which the bank focuses. The company also outlines the channels it uses, stating that it engages “directly with policy makers” and, “indirectly through, and/or provid[es] financial or in-kind support to a trade association or other intermediary organization or individual whose activities could influence policy, law, or regulation,” and it notes that it has spoken with “various local, state, and federal offices and officials” about its climate-risk management strategy. However, the disclosures stop short of detailing the precise form of each intervention (for example, comment letters, meetings, testimony) or naming the individual agencies or legislators contacted in each case. On objectives, PNC acknowledges the exchanges were “exploratory” and that it “did not propose any legislative solutions,” offering only broad aspirations such as facilitating a low-carbon transition and financing green projects, without tying these ambitions to specific policy outcomes or amendments. The result is a clear picture of what policy proposals the bank watches and the broad ways it engages, but only limited insight into the concrete results it seeks from those efforts.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	PNC has established structured oversight for its corporate political activities, noting that “all corporate political activities conducted by or on behalf of PNC are managed by our Government Affairs department, which reports to the General Counsel of PNC,” and that the Audit Committee “reviews on an annual basis… major lobbying priorities, expenditures made in support of ballot or levy issues and… total dues paid to our principal national trade associations if they exceed $25,000.” To align its external engagement with climate objectives, PNC has implemented a deliberate “signatory governance process,” designed “to move the organization seamlessly from discussion to decision to declaration to delivery,” and uses a DACI decision-making model wherein the Driver engages Contributors, who then present recommendations to an Approver—often a member of the Executive Committee such as the CEO or General Counsel—before briefing those who need to be Informed. This process explicitly evaluates requests “including those around climate change and other environmental issues” for “alignment with PNC corporate values, material ESG issues and Corporate Responsibility goals.” However, while this framework addresses sign-on requests and indirect engagement, the company does not disclose a formal mechanism for reviewing its direct lobbying positions in light of its climate commitments, nor does it provide criteria for ensuring the lobbying activities of trade or industry associations are aligned with its Climate Action Strategy, and there is no public audit or dedicated review report on climate lobbying alignment.	2