Capital One Financial Corp

Capital One Financial Corp discloses a formal oversight structure for its political activities; a "Committee of the Board, which is composed entirely of independent directors, oversees the Corporation's governance policies regarding political activity and expenditures" and this committee "approves on an annual basis the corporation's contribution criteria, spending guidelines and total corporate expenditure budget" while also "reviewing on an annual basis the Corporation's political contributions ... and the Corporation's Government and Policy Affairs Group Annual Report." Requests for political contributions are "evaluated by the Contributions Committee and approved by the Vice President, Head of Government and Policy Affairs," and contributions are "reported semi-annually." However, the company does not disclose any process to align its lobbying efforts - direct or through trade associations - with its broader corporate or climate policy objectives, nor any climate-focused auditing or review mechanisms.