Legal & General Group PLC

#### • [Does the company disclose its climate-related lobbying/advocacy activities, including trade association ] memberships, and explain the action it will take if these are not aligned with a 1.5°C scenario?

#### • [Does the company disclose its climate-related lobbying/advocacy activities, including trade association ] memberships, and explain the action it will take if these are not aligned with a 1.5°C scenario?

Underpinning our approach is LGIM's governance structure, which is aimed at ensuring rigour and accountability, as well as enabling us to continue meeting the highest standards of oversight for our clients' investments and LGIM's corporate commitments. We believe that responsible investment activity needs to be fully integrated and overseen across LGIM's formal governance committees, including our Executive Committee, as well as a specific board-level Investment Stewardship Committee, which is chaired by an independent non-executive director. Our governance structure continued to evolve during 2022 and while the executive governance structure was largely maintained, the approach to overseeing ESG was further developed. The Responsible Investment Oversight Committee was established as a sub-committee of the Investment Oversight Committee, to oversee the delivery of our responsible investment portfolios' characteristics. We also established a number of working and project groups to ensure we are meeting our objectives and continuing to deliver value for our clients and all stakeholders. **CEO** The implementation and oversight of our responsible investment strategy continues to be overseen and supervised by the highest level of governance bodies at the executive and board level.

#### • [Does the company disclose its climate-related lobbying/advocacy activities, including trade association ] memberships, and explain the action it will take if these are not aligned with a 1.5°C scenario?

The 2024 season also saw LGIM co-file its first shareholder resolution in Japan, at Nippon Steel – the largest steel maker in Japan and one of the largest globally in terms of production – calling on the company to become a regional leader on climate-related lobbying disclosures. [...] Highlighting progress [...] Climate lobbying and climate governance also witnessed notable progress.

Transparency is key – companies must be consistent in what they declare publicly and how they lobby governments behind the scenes. And investors must be transparent about how they assess companies. By making our climate ratings publicly available, we want to encourage companies to address gaps in their disclosures and strategies, whilst adding a layer of public accountability.

###### • [The Paris Agreement requires a supportive ]\n\npolicy environment. In light of this, we set a\n['red line' for all sectors on the disclosure of](https://www.lgimblog.com/categories/esg-and-long-term-themes/climate-lobbying-turning-up-the-heat/)\n[climate lobbying activities. This includes trade](https://www.lgimblog.com/categories/esg-and-long-term-themes/climate-lobbying-turning-up-the-heat/)\nassociation memberships, and explaining\nwhat actions a company will take if the\nlobbying activities of these associations are\nnot aligned with a 1.5°C scenario [...] \n\n###### • [In addition to our new 'red line' on climate lobbying ]\n\napplied to all sectors, we expect companies\nto meet certain sector-specific 'red lines'\n(please see Appendix) [...] \n\n|Sector|Our expectations|Engagement analysis|\n|---|---|---|\n|Steel|Decarbonising industrial processes and increasing recycling rates.|The decarbonisation of the steel industry requires a supportive policy environment as well as corporate aspiration, so we have added a red line related to the disclosure of climate-related lobbying activities to our sector guides. Tata Steel* has improved its climate ambition significantly over the past 12 months, as it has committed to net-zero emissions globally by 2045. As a result, the company now meets this red line, and we hope to continue our engagement with the company as it transitions. We also hope to continue engaging with companies on the development of international certification standards for 'green-steel' production.

#### Red lines
• [Does the company have a net-zero operational emissions target?]
• [Does the company disclose its climate-related lobbying/advocacy activities, including trade association ]
memberships, and explain the action it will take if these are not in line with the Paris Agreement?

LGIM's expectations for 'dial-mover' companies now include: [...] To achieve the policy environment requirement in the Paris Agreement, LGIM has set a 'red line' for all sectors on the disclosure of climate lobbying activities, including trade association memberships, and explaining what actions it will take if the lobbying activities of these associations are not aligned with a 1.5°C scenario.

#### Collaboration
• [How is the company working collaboratively across its value chain to reduce emissions (e.g. with tenants, material manufacturers, construction firms, sector initiatives, etc.)?

#### • [Is the company advocating meaningful policy action, including from regulators, to meet global net-zero targets (e.g. with carbon pricing)?]

#### Red lines
• [Does the company disclose its property portfolio's operational emissions, and has it set a reduction target for them?

#### • [Does the company disclose its climate-related lobbying activities, including trade association memberships, and explain the action it will take if these are not aligned with a 1.5°C scenario?]

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]LGIM engages internationally and domestically, both directly with policymakers and indirectly with trade associations to accelerate the transition to net zero LGIM's dedicated ESG Policy Lead works with colleagues across the business – including our parent L&G Group - to ensure a coordinated and consistent approach to influencing policy, law or regulation and that this is aligned with our climate strategy and commitment to net zero.

LGIM's governance structures enable oversight and accountability of our policy work. In 2021, these were enhanced in line with our drive to meet the highest standards of oversight of our clients' investments and LGIM's corporate commitments, including our net zero commitment. The Investment Stewardship Committee reports to LGIM's CEO and the LGIM(H) Board, while the Net Zero Working Group and the Responsible Investment Oversight Committee report to LGIM's Executive Committee, up to the CEO and Board. Additionally, members of LGIM's Executive Committee, including the CIO, Head of Responsible Investment Integration and Head of Stewardship sit on the L&G Group Environment Committee – focused on the Group's strategic response to climate change and reporting into the Group ExCo and Board.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]LGIM engages internationally and domestically, both directly with policymakers and indirectly with trade associations to accelerate the transition to net zero LGIM's dedicated ESG Policy Lead works with colleagues across the business – including our parent L&G Group - to ensure a coordinated and consistent approach to influencing policy, law or regulation and that this is aligned with our climate strategy and commitment to net zero. LGIM's governance structures enable oversight and accountability of our policy work. The Investment Stewardship Committee reports to LGIM's CEO and the LGIM(H) Board, while the Net Zero Working Group and the Responsible Investment Oversight Committee report to LGIM's Executive Committee, up to the CEO and Board. Additionally, members of LGIM's Executive Committee, including the CIO, Head of Investment Stewardship and Responsible Investment Integration are represented on the L&G Group Environment Committee – focused on the Group's strategic response to climate change and reporting into the Group ExCo and Board.