Realty Income Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Realty Income Corp’s disclosures focus on ESG oversight, but they do not address governance of lobbying activities. The company describes that "we created a Sustainability Department, which reports to the Executive Vice President, Chief Legal Officer, General Counsel & Secretary, with oversight from the Nominating/Corporate Governance Committee of the Board of Directors" and that "Our Board’s Nominating/Corporate Governance Committee maintains direct oversight of the Company’s ESG initiatives." It also states that "an Enterprise Risk Management evaluation is conducted annually to identify and assess our risks, including climate-related risks" and that "Our Board’s Compensation and Talent Committee’s annual compensation reviews for our executive officers also includes discussions of ESG matters." However, the company does not disclose any policy or process for governing or aligning its lobbying activities, nor does it identify any individual or committee responsible for overseeing lobbying or political engagement. View Sources	E

Overall Assessment

Analysis

Score

None

Realty Income Corp’s disclosures focus on ESG oversight, but they do not address governance of lobbying activities. The company describes that "we created a Sustainability Department, which reports to the Executive Vice President, Chief Legal Officer, General Counsel & Secretary, with oversight from the Nominating/Corporate Governance Committee of the Board of Directors" and that "Our Board’s Nominating/Corporate Governance Committee maintains direct oversight of the Company’s ESG initiatives." It also states that "an Enterprise Risk Management evaluation is conducted annually to identify and assess our risks, including climate-related risks" and that "Our Board’s Compensation and Talent Committee’s annual compensation reviews for our executive officers also includes discussions of ESG matters." However, the company does not disclose any policy or process for governing or aligning its lobbying activities, nor does it identify any individual or committee responsible for overseeing lobbying or political engagement.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E