Marsh & McLennan Cos Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Marsh & McLennan discloses a substantial amount of detail on its climate-policy lobbying. It names several concrete initiatives it has engaged on, including participation in the EU Commission’s Climate Resilience Dialogue, engagement with the U.S. Treasury and the Federal Insurance Office on (re)insurance and global food-security issues, and contributions to the Commodity Futures Trading Commission’s Climate-Related Market Risk Advisory Committee and its report “Managing Climate Risk in the U.S. Financial System.” The company is equally clear about how it lobbies: it describes direct meetings with Members of the European Parliament and the European Commission, discussions with the Biden Administration’s National Security Council, and service on the CFTC advisory committee, noting that “Our Government Relations team represents our public policy priorities by strategically engaging policymakers and external stakeholders.” Marsh & McLennan also explains what it is trying to achieve, seeking regulatory steps that will allow community-based catastrophe insurance to strengthen disaster preparedness, policy support for Ukrainian grain exports and wider food security, and U.S. financial-regulatory action to “measure, understand, and address climate-related risks urgently and decisively,” alongside broader calls for financial innovation to facilitate the net-zero transition. Together, these disclosures demonstrate a strong level of transparency, although the company lists only a handful of identifiable climate policies rather than a comprehensive catalogue of every engagement.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Marsh & McLennan Cos Inc has established oversight for its government relations and political contributions, but it does not disclose any process for aligning lobbying activities with its climate objectives. For instance, "Our government relations activity is subject to our code of conduct and other rules that address interactions with public officials and corporate political contributions," and "Each payment to a trade association is individually reviewed and subject to attestation," reflecting a review process for indirect lobbying expenditures. It also notes that "Marsh McLennan PAC is governed by an Advisory Committee, which administers the PAC’s budget over each two-year election cycle and oversees compliance with US federal election laws," and that PAC contributions are made "with the approval of the Advisory Committee chairperson," demonstrating defined oversight and sign-off. The company further commits to regulatory transparency by stating that it "files lobbying reports (LD-2) on a quarterly basis to disclose federal lobbying activities and expenses" and that its federal lobbyists "are required to file semiannual LD-203 reports on any personal funds contributed to federal candidates." While these disclosures indicate robust compliance and transparency processes, there is no disclosure of a climate lobbying governance policy, no mechanism to align lobbying with climate-related goals, and no individual or formal body identified as responsible for monitoring or enforcing climate-aligned advocacy.	1