Northern Trust Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Northern Trust Corp has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has disclosed specific climate-related policies it engaged with, including the "U.S. Securities and Exchange Commission's proposed new and amended rules and forms, as set forth in Release Nos. 33-11042 and 34-94478, concerning climate-related disclosures for investors," and the "International Sustainability Standards Board (ISSB) Exposure Drafts — IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures." Additionally, it has been actively involved in initiatives like Climate Action 100+ and the Institutional Investors Group on Climate Change (IIGCC), targeting sectors such as oil and gas and financial services. Northern Trust Asset Management has disclosed specific lobbying mechanisms, such as submitting comment letters to policymakers, engaging directly with corporate management, and participating in collaborative initiatives. For example, it stated, "In 2022 we submitted a comment letter relating to the U.S. Securities and Exchange Commission's proposed new and amended rules and forms," and provided a comment letter on the ISSB Exposure Drafts. Furthermore, the company identified target entities, including the U.S. Securities and Exchange Commission and the International Sustainability Standards Board, demonstrating clarity in its lobbying mechanisms and targets. The company has also articulated the outcomes it seeks through its lobbying efforts, such as advocating for companies to align their greenhouse gas reduction targets with the Paris Agreement and limit global warming to 1.5°C. Specific goals include pushing for transparency in climate-related lobbying activities, supporting the adoption of science-based emissions targets, and recommending modifications to alleviate disclosure burdens related to Scope 3 emissions. These disclosures illustrate Northern Trust Corp's clear focus on achieving measurable climate policy outcomes and its commitment to transparency in its lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Northern Trust Asset Management demonstrates a strong governance approach by outlining clear oversight structures, detailed monitoring processes, and transparent accountability measures for both direct and indirect climate lobbying. The evidence states "The Sustainable Investing Council (SIC), chaired by the Global Head of Sustainable Investing and Stewardship, provides multi-disciplinary oversight across sustainable investing practices, including climate change," and that "the NTAM Asset Management Risk Committee (AMRC)…provides oversight and governance for risks, including climate change." This governance framework is further supported by a three-lines-of-defense model for managing climate-related risks, with the Risk Management function setting direction and providing aggregate oversight. Northern Trust also actively engages with trade associations and policymakers to align its lobbying efforts with climate goals, underscoring its commitment to maintaining effective climate lobbying oversight.	3