Voya Financial Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Voya Financial discloses only limited information on how it governs policy-related engagement. It notes that "In 2021, Voya established an ESG Center of Excellence to formalize our climate strategy and communicate it with our employees, clients, and shareholders" and that this team "will work in partnership with Risk, Corporate Real Estate and Strategic Sourcing, as well as Voya's lines of business to ensure consistency of approach to Voya's commitment to environmental sustainability," implying an internal mechanism that reviews whether engagement activities align with its climate strategy. However, the disclosure does not specify whether this process covers direct lobbying, oversight of trade-association positions, or any escalation steps when misalignment is identified, nor does it identify a board committee or named executive with responsibility for such reviews. The company also states "No, and we do not plan to have one in the next two years" when asked about a public commitment to conduct engagement in line with the Paris Agreement, further indicating that its governance framework for climate-related lobbying is not clearly defined or publicly accountable. Overall, while there is a stated intention to keep engagement consistent with environmental goals, the company does not disclose comprehensive structures, monitoring procedures, or accountability mechanisms specific to lobbying activities. View Sources	D

Overall Assessment

Analysis

Score

Limited

Voya Financial discloses only limited information on how it governs policy-related engagement. It notes that "In 2021, Voya established an ESG Center of Excellence to formalize our climate strategy and communicate it with our employees, clients, and shareholders" and that this team "will work in partnership with Risk, Corporate Real Estate and Strategic Sourcing, as well as Voya's lines of business to ensure consistency of approach to Voya's commitment to environmental sustainability," implying an internal mechanism that reviews whether engagement activities align with its climate strategy. However, the disclosure does not specify whether this process covers direct lobbying, oversight of trade-association positions, or any escalation steps when misalignment is identified, nor does it identify a board committee or named executive with responsibility for such reviews. The company also states "No, and we do not plan to have one in the next two years" when asked about a public commitment to conduct engagement in line with the Paris Agreement, further indicating that its governance framework for climate-related lobbying is not clearly defined or publicly accountable. Overall, while there is a stated intention to keep engagement consistent with environmental goals, the company does not disclose comprehensive structures, monitoring procedures, or accountability mechanisms specific to lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Voya Financial provides a basic level of transparency on its climate-related public-policy engagement. It identifies two concrete policy arenas—the U.S. Department of Labor’s proposed ESG rules, to which it “provided comments,” and its public endorsement of the Task Force on Climate-Related Financial Disclosures—showing some clarity over the specific initiatives it tries to influence. The company also discloses one clear mechanism, noting that it submitted formal comments to the Department of Labor, but beyond that single example it speaks only in general terms about “engagement” and work with PwC to improve disclosure scores, without naming other government bodies or detailing additional lobbying channels. The objectives it lists are largely aspirational—for example, improving climate-related financial reporting and aligning policies with its goal to reduce and offset Scope 1, 2 and 3 emissions—rather than spelling out the precise regulatory changes it seeks. As a result, while Voya does acknowledge some direct action and articulates broad aims, the overall picture of its climate-policy lobbying remains limited in depth and specificity.	D