Great-West Lifeco Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Great-West Lifeco Inc. is notably transparent about its climate-policy lobbying. It names two identifiable rule-makings it engaged on – the U.S. SEC’s “Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social and Governance Investment Practices (File No. S7-17-22)” and “Investment Company Names (File No. S7-16-22)” – and describes broader work on national greenhouse-gas reduction and green-building strategies through Canadian industry bodies. The company also discloses how it lobbies: it “sent a letter on August 16, 2022” to the SEC, and it exerts influence indirectly by providing financial and in-kind support to trade associations such as REALPAC and the Canada Green Building Council that “collaborate with government officials to implement green building policies,” identifying both the direct (SEC) and indirect (federal and Québec government registers) targets of these efforts. Finally, the firm is explicit about the outcomes it seeks, asking the SEC to amend “the definition and specific disclosure requirements for ‘Integration Funds’,” to refine the disclosure table for “ESG-Focused Funds,” and supporting greater government incentives for energy-efficient buildings and other measures that advance Paris-aligned green-building practices. By spelling out the specific policies addressed, the mechanisms used, and the concrete policy changes it advocates, the company demonstrates a high level of transparency across its climate-lobbying disclosures.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Great-West Lifeco maintains an established governance process for its climate-related policy influencing, with “an annual review of our direct and indirect activities that influence public policy” conducted by its Community Relations Department “to ensure relevancy, efficacy and consistency of approach and strategy” and assessing them “for consistency with our overall climate change strategy.” This includes both direct advocacy and indirect activities through voluntary sector groups, and extends to its investment subsidiaries via “specific internal processes” noted in their stewardship reports, as exemplified by ILIM’s pledge “to advocate for climate action with policy makers, investors, and industry groups.” The company also affirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the company does not disclose a specific individual or formal board committee with oversight of its lobbying alignment nor provide detail on how the outcomes of its annual review drive corrective or escalation measures beyond aligning new initiatives with “annual strategic objectives.”	2