MarketAxess Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	MarketAxess has established a basic framework for overseeing its lobbying activity, with “the Company’s General Counsel” given responsibility to oversee “the Company’s PAC’s political contributions, payments to lobbyists, and payments to trade associations that use a portion of the dues for lobbying activity,” and to “periodically update the Nominating and Corporate Governance Committee of MarketAxess’ Board of Directors on the Company’s PAC’s political contribution and lobbying activities and the Company policies that govern these activities.” Furthermore, “on an annual basis, the Nominating and Corporate Governance Committee reviews MarketAxess’ lobbying activities and budget, including trade association memberships, to assess the value of these activities and ensure alignment with MarketAxess’ positions and interests.” However, the company does not disclose any processes specifically governing climate-related lobbying nor any commitment to align its engagement with the goals of the Paris Agreement, explicitly stating “No, and we do not plan to have one in the next two years.” This indicates limited governance focused on general lobbying oversight without addressing climate lobbying alignment. View Sources	D

Overall Assessment

Analysis

Score

Limited

MarketAxess has established a basic framework for overseeing its lobbying activity, with “the Company’s General Counsel” given responsibility to oversee “the Company’s PAC’s political contributions, payments to lobbyists, and payments to trade associations that use a portion of the dues for lobbying activity,” and to “periodically update the Nominating and Corporate Governance Committee of MarketAxess’ Board of Directors on the Company’s PAC’s political contribution and lobbying activities and the Company policies that govern these activities.” Furthermore, “on an annual basis, the Nominating and Corporate Governance Committee reviews MarketAxess’ lobbying activities and budget, including trade association memberships, to assess the value of these activities and ensure alignment with MarketAxess’ positions and interests.” However, the company does not disclose any processes specifically governing climate-related lobbying nor any commitment to align its engagement with the goals of the Paris Agreement, explicitly stating “No, and we do not plan to have one in the next two years.” This indicates limited governance focused on general lobbying oversight without addressing climate lobbying alignment.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E