Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Limited |
Apollo Global Management discloses that "our participation in the public policy arena and expenditures related thereto are managed by the Public Policy department, overseen by the Global Head of Public Policy who reports to the Chief Executive Officer," and that oversight also involves the Board-level Sustainability and Corporate Responsibility Committee which is "responsible for assisting the Board of Directors in overseeing corporate responsibility and sustainability matters, including climate change considerations." In addition, a cross-functional "Reputational Risk Working Group (“RRG”) closely monitors regulatory and reputational risk management" and "generally meets weekly to review internal and external dynamics," suggesting a recurring forum in which lobbying-related risks can be escalated. These disclosures indicate that named individuals and committees have formal responsibility for supervising the firm’s public-policy engagement, which points to a basic governance structure. However, the company does not disclose any policy or procedure that specifically evaluates whether its direct or indirect lobbying positions align with its climate objectives, makes no mention of reviewing or influencing trade-association positions, and provides no detail on monitoring or auditing climate-related advocacy. Therefore, while oversight bodies are identified, the underlying mechanisms for ensuring climate-lobbying alignment, detailed monitoring, or corrective action are not publicly described.
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D |