Principal Financial Group Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Principal Financial Group has established a governance framework to ensure its lobbying activities align with its climate change strategy, with senior leaders tied to this oversight and accountability. The company explains that “Principal executive management team is responsible for providing environmental high level initiatives that are aligned with the company’s overall climate change strategy,” and that “aligning environmental high level initiatives with the company’s overall climate strategy and tying the completion of the high level initiatives to compensation ensures that all engagement is consistent across the company.” It further clarifies that “Principal Asset Manager IV oversees the ESG Task Force and is charged with ensuring that all of our direct and indirect activities that influence policy are consistent with our overall climate change strategy,” and that “the responsibility to review environmental and social responsibility matters of significance to Principal was added to the Nominating and Governance Committee’s charter in 2012, reflecting the Board of Directors’ interest in these matters.” However, the company does not disclose a public commitment to conduct its engagement in line with the goals of the Paris Agreement, and we found no evidence of a dedicated climate-lobbying audit or detailed review processes for its indirect lobbying through trade associations. View Sources	B

Overall Assessment

Analysis

Score

Strong

Principal Financial Group has established a governance framework to ensure its lobbying activities align with its climate change strategy, with senior leaders tied to this oversight and accountability. The company explains that “Principal executive management team is responsible for providing environmental high level initiatives that are aligned with the company’s overall climate change strategy,” and that “aligning environmental high level initiatives with the company’s overall climate strategy and tying the completion of the high level initiatives to compensation ensures that all engagement is consistent across the company.” It further clarifies that “Principal Asset Manager IV oversees the ESG Task Force and is charged with ensuring that all of our direct and indirect activities that influence policy are consistent with our overall climate change strategy,” and that “the responsibility to review environmental and social responsibility matters of significance to Principal was added to the Nominating and Governance Committee’s charter in 2012, reflecting the Board of Directors’ interest in these matters.” However, the company does not disclose a public commitment to conduct its engagement in line with the goals of the Paris Agreement, and we found no evidence of a dedicated climate-lobbying audit or detailed review processes for its indirect lobbying through trade associations.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Principal Financial Group provides only limited visibility into its climate-related public-policy engagement. It names one relevant measure it sought to influence—the U.S. Department of Labor’s proposed rule on “Prudence and Loyalty in Selecting Plan Investments” and related federal legislation—showing some specificity but not breadth regarding the policies on which it intervenes. The company does describe how it engages, noting that it “actively engaged with lawmakers and regulators to help craft a final regulation,” in addition to using industry forums and collaborative working groups, thereby revealing at least two clear mechanisms and the governmental targets of those efforts. It is also explicit about the single outcome it pursued, stating that it “argued that the DOL proposal should enable consideration of ESG criteria by a fiduciary when making retirement plan investment decisions” and that it opposed attempts to unwind the rule. Beyond this single example, however, the disclosures do not identify other climate-related laws, the governmental bodies addressed, or the specific changes the company seeks, leaving large gaps in understanding the scope and objectives of its lobbying activity.	D