Brown-Forman Corp

Brown-Forman has a defined governance process for its political contributions, noting that its "internal procedures [are] designed to align these efforts with our public policy priorities and applicable law," that "all political contributions using corporate funds must be approved by the Vice President, Director Public Affairs, Americas," and that the Corporate Governance and Nominating Committee "will annually review such activities and related policies" based on reports from its public affairs lead. Its Audit Committee and Corporate Governance Committee also "share oversight over the risks and disclosure of risks related to environmental, social, and governance matters," and the company adopted its "Political Engagement and Contributions Policy" in 2020 to bolster transparency around political activity. However, we found no evidence of any mechanism to align or monitor its direct lobbying or its trade‐association memberships against climate objectives, no public report or audit evaluating climate lobbying, and the company confirms that it has "no plan" to commit its engagement activities to the goals of the Paris Agreement.