US Bancorp

Lobbying Governance

AI Extracted Evidence Snippet Source

Direct and indirect activities are reviewed and approved by a level of senior management not more than three levels removed from the CEO. The ultimate decision is made in collaboration with the Senior Executive Vice President, Chief Social Responsibility Officer, and is reflective of U.S. Bancorp's climate change strategy and policy. As it relates to strategic planning and overall direction of our ESG efforts, activities would also be reviewed and approved by the ESG Committee, comprised of senior leaders representing business and enablement functions across the company.

https://www.usbank.com/dam/en/documents/pdfs/common/usbankcorp-cdp-web-2023.pdf

###### Public Responsibility Committee (PRC): This committee oversees our management of reputation risk and reviews our company's reputation, culture and brand management activities; reviews and considers our position and practices on matters of public interest and public responsibility; reviews public policy matters that impact our company's business activity, financial performance or reputation; oversees our policies and programs related to corporate responsibility; and oversees our ESG strategy. The PRC receives regular updates from management on the company's ESG strategy and climate-related goals and commitments, including progress on our goal announced in November 2021 to achieve net zero greenhouse gas emissions by 2050. The PRC receives information from management on priorities to achieve our ESG commitments, relevant timelines, and related metrics in order to oversee and hold management accountable for progress. The PRC also oversees our ESG disclosure and communication plans. [...] Instances of non-adherence or violations of the policy are monitored and may be factored into employee incentive compensation decisions.

https://www.usbank.com/dam/documents/pdf/about-us-bank/community/2021-TCFD-Report.pdf

###### Public Responsibility Committee (PRC)
This committee oversees our management of
reputation risk and reviews our company's reputation,
culture and brand management activities; reviews and
considers our position and practices on matters of
public interest and public responsibility; reviews public
policy matters that impact our company's business
activity, financial performance or reputation; oversees
our policies and programs related to corporate
responsibility; and oversees our ESG strategy. The
PRC receives regular updates from management
on the company's ESG strategy and environmental
goals and commitments. This information includes
considerations for achieving our ESG commitments,
relevant timelines and related metrics in order to
overseen and hold management accountable for
progress. The PRC also oversees our ESG disclosure
and communication plans. [...] **Due diligence**
We have a robust mechanism for due diligence. For
relationships that present heightened risk, additional
due diligence is performed to evaluate risks specific
to that customer. The additional due diligence
includes an assessment of a variety of risk factors
such as past compliance with laws and regulations,
as well as customer programs in place that mitigate
the potential for operational, reputation, compliance
and credit risks. Our environmental due diligence
requirement applies to all prospective and existing
customer relationships meeting specific internal
exposure thresholds. [...] Once due diligence is complete,
relationships with heightened risk are escalated
through a formal approval process that may require
review by business line and risk executives, including
U.S. Bancorp's chief risk officer and other Managing
Committee members, as appropriate. Instances of non-adherence or violations of company
policy are monitored and may be factored into
employee incentive compensation decisions.

https://www.usbank.com/dam/en/documents/pdfs/common/tcfd-report-2022.pdf

Direct and indirect activities are reviewed and approved by a level of senior management not more than three levels removed from the CEO. Potential engagement opportunities are brought to the attention of our Environmental Program Manager who reviews them within the context of our Environmental and Social Risk Policy, as well as U.S. Bancorp's established environmental strategy. The Environmental Program Manager takes the opportunity to the appropriate business line partners, depending on the focus of the opportunity, for feedback. The ultimate decision is made in collaboration with the Executive Vice President, Chief Social Responsibility Officer and is reflective of U.S. Bancorp's climate change strategy and policy. As it relates to strategic planning and overall direction of our ESG efforts, activities would also be reviewed and approved by the ESG Committee and Climate Risk Working Group. Both are comprised of senior leaders representing business and enablement functions across the company.

https://www.usbank.com/dam/en/documents/pdfs/common/usbankcorp-cdp-web-2022.pdf

### Escalation and monitoring protocols

The Company's risk and business line functions collaborate to monitor, assess and act on external information or events that may have operational, reputational, compliance, or credit risk impacts to the Company. Impacts are assessed to determine appropriate risk mitigation actions. These activities supplement other activities that identify proposed or current relationships that meet existing ESRP criteria for escalation.

Business lines may be required to document and implement any identified mitigation activities prior to receiving approval to enter or expand a relationship with heightened risk. The risk mitigation activities must specifically address the risk associated with the relationship and could include activities such as enhanced monitoring and periodic reviews. Once due diligence is complete, relationships with heightened risk are escalated through a formal approval process that may require review by business line and risk executives. The Company's Chief Risk Officer and other Managing Committee members may be engaged when appropriate.

Instances of non-adherence to or violations of Company policy are monitored and may be factored into incentive compensation decisions.

https://www.usbank.com/dam/documents/pdf/about-us-bank/community/Ethics/environmental_and_social_risk_policy_statement.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Direct and indirect activities are reviewed and approved by a level of senior management not more than three levels removed from the CEO. Potential engagement opportunities are brought to the attention of our Environmental Program Manager who reviews them within the context of our Environmental and Social Risk Policy, as well as U.S. Bancorp's established environmental strategy. The Environmental Program Manager takes the opportunity to the appropriate business line partners, depending on the focus of the opportunity, for feedback. The ultimate decision is made in collaboration with the Executive Vice President, Chief Social Responsibility Officer and is reflective of U.S. Bancorp's climate change strategy and policy.

As it relates to strategic planning and overall direction of our ESG efforts, activities would also be reviewed and approved by the ESG Committee and Climate Risk Working Group. Both are comprised of senior leaders representing business and enablement functions across the company.

CDP Questionnaire Response 2022

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]No, and we do not plan to have one in the next two years

CDP Questionnaire Response 2023