MSCI Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive MSCI Inc discloses an extensive and detailed picture of its climate-policy lobbying. It names a wide range of specific initiatives it has engaged on, including the U.S. SEC’s proposed rule on “The Enhancement and Standardization of Climate-Related Disclosures for Investors,” the EU Sustainable Finance Package (EU taxonomy, EU Green Bond Standard, climate benchmarks and ESG benchmark disclosures), the UK Government’s Green Finance Strategy, the FDIC’s “Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions,” India’s consultation on “Green and Blue Bonds as a mode of Sustainable Finance,” and EU prudential and banking consultations, among others. It is equally clear about how it lobbies and whom it targets: the company describes “respond[ing] to the public consultation” of the Securities and Exchange Board of India, taking part in the “EU Commission’s 35-member Technical Expert Group,” holding a “discussion with the New York State Department of Financial Services,” providing written recommendations to the FDIC, and submitting comments to the UK Treasury, EBA and EFRAG, thereby revealing both direct submissions and indirect committee work and identifying each regulatory body. MSCI also spells out the concrete outcomes it seeks. For example, it urged that “any green bond standard… should converge with the international standards,” proposed “lowering the USD $100 billion asset size threshold” in the FDIC draft to widen coverage, asked the SEC to “define a materiality assessment threshold” to improve Scope-3 comparability, advocated for a mandatory green taxonomy and transition-plan disclosures in the UK, and worked on “defining the standards for an EU Ecolabel for financial services.” By naming the policies, describing the engagement channels and pinpointing the policy changes it is pursuing, MSCI demonstrates a very high level of transparency around its climate lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate MSCI Inc discloses several elements of governance related to its lobbying activities, including climate-related aspects. The Governance and Corporate Responsibility Committee oversees environmental, social, and governance matters, with the Chief Responsibility Officer providing quarterly updates and semi-annual reports to the committee, which are also shared with the full Board. This indicates a structured oversight mechanism. Additionally, the MSCI Code of Conduct requires employees to disclose and obtain pre-approval from the Executive Committee and Compliance Department before representing MSCI in leadership roles within industry associations, ensuring alignment with company policies. Public communications are reviewed by the Legal and PR/Marketing teams, while the Government and Regulatory Affairs team reviews consultation responses and comment letters for consistency with MSCI’s positions. However, MSCI does not disclose a public commitment to align its engagement activities with the goals of the Paris Agreement, nor does it plan to adopt one in the next two years. While the company provides details on oversight and review processes, it does not explicitly address how it ensures alignment of indirect lobbying activities, such as through trade associations, with its climate strategy. This indicates moderate governance but lacks comprehensive coverage of both direct and indirect lobbying alignment. 2