Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Limited |
First Horizon Corp discloses only limited information about how it governs its lobbying and policy-engagement activities. The company indicates that its "Nominating and Corporate Governance Committee of the Board continues to have significant focus on environmental, social and governance matters" and that results of ESG assessments are "shared with the Nominating and Corporate Governance Committee of the Board, our ESG Working Group and other key stakeholders," but it does not explain any specific mechanism by which these bodies review or approve lobbying positions. The sole concrete procedural reference is in the Code of Business Conduct and Ethics, which notes that "the Company is allowed to engage with federal, state and local officials, but may be required to register as a lobbyist when doing so" and therefore "company directors, officers and associates should seek the guidance of the Company’s General Counsel before engaging in any political activities that involve the Company." This requirement to obtain General Counsel guidance suggests an oversight or sign-off step, indicating some governance of political activity, yet no details are provided on how the General Counsel or the Board evaluates alignment with the company’s climate or broader policy objectives, nor is there mention of reviewing trade-association positions or publishing any lobbying-alignment report. The company also states, "No, and we do not plan to have one in the next two years" when asked whether it has a commitment to align engagement with the goals of the Paris Agreement, underscoring that climate-specific lobbying governance is not disclosed. Overall, while there is a basic oversight touchpoint, the company does not disclose processes, responsible individuals or committees specifically charged with monitoring lobbying alignment, nor any coverage of indirect lobbying, indicating only limited governance transparency.
View Sources
|
D |