Commerce Bancshares Inc/MO – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Commerce Bancshares has strengthened its ESG governance with the formation of “an ESG Management Committee” and “board level oversight,” alongside a “Sustainability Task Force” and enhanced disclosures and reporting, but the company does not disclose any governance process related to lobbying activities or climate-related lobbying alignment. We found no evidence of a policy, committee, or individual responsible for overseeing lobbying engagement, nor any monitoring or review steps to ensure that its direct or indirect lobbying aligns with climate or policy objectives, leaving lobbying governance unaddressed in its disclosures. View Sources	E

Overall Assessment

Analysis

Score

None

Commerce Bancshares has strengthened its ESG governance with the formation of “an ESG Management Committee” and “board level oversight,” alongside a “Sustainability Task Force” and enhanced disclosures and reporting, but the company does not disclose any governance process related to lobbying activities or climate-related lobbying alignment. We found no evidence of a policy, committee, or individual responsible for overseeing lobbying engagement, nor any monitoring or review steps to ensure that its direct or indirect lobbying aligns with climate or policy objectives, leaving lobbying governance unaddressed in its disclosures.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E