Manulife Financial Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Manulife Financial Corp provides an extensive and specific picture of its climate-policy lobbying. It names multiple identifiable regulatory initiatives it has engaged on, including the “OSFI B15 Guideline Consultation,” the “Canadian Securities Administrators (CSA) Disclosure Consultation,” the U.S. “Securities and Exchange Commission (SEC) ESG Disclosure Consultation,” and even legislative matters such as an “Amendment to the Clean Air Act,” demonstrating full transparency about the policies it seeks to influence. The company also explains how it engages and with whom: its Government Relations team “manages our engagement with regulators and policymakers,” it offers “technical assistance throughout the legislative negotiation process,” submits direct commentary to the SEC, meets with “Members of Congress and staff” and with “Federal and Provincial Governments of Canada,” and works indirectly through industry bodies such as the American Council of Life Insurers and the National Alliance of Forest Owners. By identifying concrete mechanisms—letters, consultations, technical assistance, coalition statements—and naming the targets (OSFI, CSA, SEC, IAIS, U.S. Congress, Canadian federal and provincial governments), the disclosure leaves little ambiguity about the channels it uses. Finally, Manulife is explicit about the outcomes it is pursuing: it “supports mandatory climate-change disclosure requirements” at the SEC, seeks to “clarify the treatment of carbon emissions from forest biomass as carbon beneficial,” backs the OSFI and CSA climate-risk frameworks “with minor exceptions,” and advocates amendments that would let insurers invest in infrastructure to facilitate the low-carbon transition. By coupling clear policy positions with the reasons for them—“to contribute to informed government decision-making” and ensure alignment with the Paris Agreement—the company sets out its lobbying objectives in a detailed and measurable way. Taken together, these disclosures show a comprehensive level of transparency across policies lobbied, mechanisms used, and outcomes sought.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Manulife’s disclosures indicate a moderate governance process for aligning its lobbying with climate objectives. The company’s sustainability governance framework, ‘‘Our sustainability governance framework enables us to achieve our sustainability objectives across our global franchise,’’ is led by the Global Chief Sustainability Officer and a ‘‘Global Climate Change Taskforce [that] drives the development of the climate strategy, risk management activities on climate-related matters, performance tracking and disclosures’’ and supports execution of a climate action plan. At the same time, Manulife ‘‘regularly report[s] on lobbying activity, as required, to ensure accountability and transparency,’’ with the General Counsel, Global Head of Government Relations, Segment CEOs, and the Board’s Audit Committee overseeing public policy activities. Moreover, the Manulife Investment Management Engagement team ‘‘meets regularly with the Global Sustainability team at Manulife to discuss company policy and to ensure advocacy aligns with these goals,’’ and employees must obtain ‘‘specific authorization’’ and pre-clear non-routine government interactions. While these elements reveal a clear policy, named leaders, and concrete processes to align direct lobbying with climate and sustainability goals—reinforced by a ‘‘public commitment … to conduct … engagement activities in line with the goals of the Paris Agreement’’—the company does not disclose a dedicated audit or independent review of its climate lobbying, nor does it describe a formal process for assessing or correcting the climate positions of trade associations through which it engages indirectly.	2