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Bread Financial Holdings Inc does not disclose any governance processes for ensuring its lobbying activities are aligned with its climate change strategy. The company explains that "Our public policy strategy includes a variety of activities aligned around defending our business interests while also balancing what is right for the greater good," and notes that "We engage in the public policy process through trade associations, industry coalitions and lobbying activity." It further states that "Oversight of climate-related risks is included in the Board’s broader sustainability governance structure," describing the roles of its Nominating & Corporate Governance Committee and Risk & Technology Committee in climate risk oversight. However, the company does not disclose any specific mechanisms for reviewing or aligning its lobbying activities with its climate goals, no policy requiring sign-off or review of climate lobbying, and no individual or formal body responsible for overseeing how lobbying aligns with its climate strategy. We found no evidence of a climate lobbying review process or criteria for assessing participation in trade associations based on climate positions.
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