Invesco Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Invesco provides a detailed and specific picture of its climate-policy lobbying. It names multiple regulatory initiatives it has worked on, including the FCA’s Sustainability Disclosure Requirements and investment-label rules, the European Commission’s reforms to the SFDR, the development of the UK green taxonomy, and work on the EU Sustainable Taxonomy and emerging IFRS climate-reporting standards, clearly identifying the jurisdictions and themes involved. The company also explains how it lobbies and who it targets: it “engaged directly with policymakers through bilateral meetings and written submissions to consultation processes,” “provided feedback to the FCA’s Disclosure and Labelling Advisory Group,” “participated in the European Commission’s consultations on SFDR reforms,” and its “Head of EU Government Relations and Public Policy represented the company in advising the UK Government on green taxonomy development.” These examples demonstrate the use of direct consultations as well as indirect channels such as trade associations and investor coalitions, and they identify concrete policymaking bodies such as the FCA, the European Commission, the UK Climate Risk Forum and the Green Technical Advisory Group. Finally, Invesco is explicit about what it is trying to achieve: it “proposed pragmatic changes to the FCA’s investment product categorization and labelling regime to make the rules more effective,” “advocated for improvements to the SFDR disclosure regime to better serve retail investors,” and “supported the development of the UK’s green taxonomy to align financial services with sustainability goals,” alongside broader support for integrating climate and sustainability risks into financial regulation. Together, these disclosures show a high level of transparency across the policies engaged, the mechanisms employed, and the specific outcomes sought. 4
Lobbying Governance
Overall Assessment Comment Score
Limited Available disclosures provide only limited insight into how Invesco governs climate-related lobbying. The company notes that “Invesco’s chief executive officer and the Invesco Ltd. Board of Directors have general supervisory oversight responsibility for the company’s activities and policies” and that “Senior Management oversees our day-to-day engagement, including through our cross-functional regulatory change committees,” indicating that senior leadership is nominally accountable for policy engagement. However, apart from this high-level statement of oversight, we found no evidence of a defined review, monitoring, or escalation process to ensure lobbying positions are aligned with Invesco’s climate strategy, nor any reference to assessing or managing the climate positions of trade associations. The statement that “The Board is responsible for setting, maintaining and regularly reassessing the policies and processes to manage the firm’s overall exposure to risk” is broad and does not describe specific mechanisms for lobbying alignment. The company also confirms that it has “No” public commitment “to conduct [its] engagement activities in line with the goals of the Paris Agreement,” which further limits transparency on climate-lobbying governance. Overall, disclosure is limited to identifying who holds general oversight, while the procedures, monitoring details, and coverage of indirect lobbying are not disclosed. 1