Western Alliance Bancorp

Lobbying Governance & Transparency

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Lobbying Governance
Overall Assessment Analysis Score
Limited Western Alliance Bancorp has established a formal, written Political Activities & Gifts to Government Officials Policy, which was “adopted by its Enterprise Risk Management Committee and reviewed annually” and “covers political contributions, state and local ‘pay-to-play’ regulations, lobbying and gifts to government officials,” and requires that “no employee may engage in lobbying activities on behalf of the Company or its subsidiaries unless that employee obtains prior authorization from the Director of Government Relations,” demonstrating a defined approval process for lobbying. This policy applies to both in-house employees and external vendors and extends to trade associations, but the company does not disclose any mechanism to align its direct or indirect lobbying with climate-related objectives or any climate-specific oversight, nor does it publish an audit or review assessing such alignment. While the ESG Executive Committee and board Governance Committee guide and oversee broad ESG priorities, we found no evidence that they review or manage the company’s lobbying activities in relation to its climate goals.

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D
Lobbying Transparency
Overall Assessment Analysis Score
Limited Western Alliance Bancorporation provides only limited visibility into its climate-related lobbying. It notes that it conducts lobbying "through in-house employees and external vendors" and that it complies with "federal, state and local lobbying registration and disclosure laws," but it does not identify which government bodies or officials it approaches. The company offers no information on the specific climate policies, legislation or regulations it has engaged on, nor does it explain what changes or outcomes it is seeking from those activities. As a result, readers can see that the bank undertakes some form of lobbying, yet gain little insight into the policy areas addressed, the targets of its advocacy, or the positions it promotes.

D