T Rowe Price Group Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive T. Rowe Price Group provides a detailed and specific picture of its climate-policy advocacy. It identifies multiple concrete measures it has worked on, naming, for example, the “Ontario Climate Change Adaptation and Resilience Act, 2024,” its feedback on Canada’s forthcoming “mandatory climate-related financial reporting and sustainable investment taxonomy,” formal submissions on the US SEC’s proposed climate-disclosure rule, responses to the UK FCA’s Sustainability Disclosure Requirements, participation in Malaysia’s National Sustainability Reporting Framework consultation (covering IFRS S1 and S2), and dialogue with Serbian officials about adopting the EU Climate Law and committing to net-zero by 2050. The company also explains how it lobbied: it describes “direct submissions to regulatory bodies such as the US SEC, UK FCA, and US Department of Labor,” “engag[ing] with representatives of the Canadian federal government, including the Deputy Director of Environment and Climate Change,” holding meetings with Ontario officials on mass-transit electrification, completing the Securities Commission Malaysia survey, and “direct discussions with Serbian Ministry of Finance” staff—clearly linking each activity to a named public-sector target. Finally, the firm is explicit about the results it is pursuing, seeking alignment between federal and provincial adaptation plans, backing a principles-based disclosure framework and core climate metrics at the SEC, urging the FCA to “prevent greenwashing and enhance transparency,” promoting green-bond issuance and nature-positive incentives in Canada, supporting electrification of Ontario’s transit system, and pressing Serbia to “decarboniz[e] coal-fired electricity generation” and lift renewable generation to around 34 % by 2030. Taken together, these disclosures demonstrate a comprehensive level of transparency about what climate policies the firm engages on, how it engages, and the concrete outcomes it is advocating. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate T. Rowe Price Group Inc. appears to have a defined governance process for its ESG advocacy, including climate-related lobbying, centered on its Public Policy Engagement and Political Participation Policy which governs the firms approach to advocacy, including through our participation in trade associations. Oversight of these activities is assigned to a newly established global ESG Oversight Committee (ESGOC) chaired by the head of ESG Enablement, and the company explains that Starting in 2024, ESGOC will review on an annual basis how our direct and indirect ESG advocacy aligns with our commitment to NZAM and the Principles for Responsible Investment (PRI). The policy also designates the Legislative and Regulatory Affairs team to manage execution and stipulates that On an ongoing basis, the LRA team will assess this alignment for relevant advocacy projects and follow escalation procedures in case of nonalignment, thus providing both monitoring and escalation mechanisms. The firm further illustrates its direct lobbying efforts by noting its responses to regulatory consultations, stating, In 2023, we responded to two consultations conducted by the UK government, where we expressed support for the UKs adoption of both of the ISSB standards: IFRS S1 (general sustainability) and S2 (climate-related) disclosure standards. However, we found no evidence of a publicly available dedicated climate-lobbying alignment report or a third-party audit of its lobbying practices, and the timeline for applying the new review process does not reflect retrospective assessments. Moreover, while the policy references indirect advocacy through trade associations, it does not detail specific criteria or thresholds for evaluating or exiting associations whose positions conflict with the firms net zero commitments. 2