Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Moderate |
Universal Health Services discloses a formal “Political and Advocacy Activity Policy” that is “overseen by the UHS General Counsel or his or her designee,” with the General Counsel required to “make reports to the Audit Committee of the UHS Board of Directors regarding UHS political and advocacy activities” and the Board “will review UHS’s Political and Advocacy Activity Policy as appropriate,” demonstrating a named oversight structure and periodic Board-level review. The policy establishes a concrete approval mechanism that covers both direct and indirect advocacy, stating that “the UHS General Counsel’s office reviews and approves contributions made by the SSF,” that “no corporate funds…may be used…unless it has been approved, in advance, by the UHS General Counsel’s office,” and that “prior to joining or contributing to a third-party advocacy group…employees must consult with and obtain the approval of the UHS General Counsel’s office.” These provisions indicate that lobbying expenditures and participation in trade or advocacy organisations require advance sign-off, suggesting an alignment process for both channels. However, the disclosure does not mention any specific criteria used to assess alignment with climate policy goals, nor does it reference a formal review of trade-association climate positions or the publication of a lobbying-alignment report, leaving the climate dimension and transparency of its review procedures unspecified. Overall, the company exhibits clear oversight and approval processes for political engagement, but it does not disclose how, or whether, these processes ensure that lobbying activities support its climate objectives.
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