Franklin Resources Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Franklin Resources Inc. discloses that its Sustainability and Stewardship Council oversees the approaches of its investment managers to ensure consistency in engagement with its climate goals, stating that the council "is able to oversee the approaches by each of our investment managers to ensure consistency in engagement with our climate goals." Additionally, the firm highlights that the Stewardship and Sustainability Council and the Global Sustainability Strategy Team have identified climate change as a key strategic priority and are collaborating with internal stakeholders and clients to implement this agenda. However, the company does not provide detailed information about specific processes, mechanisms, or monitoring frameworks for lobbying alignment, nor does it explicitly address direct or indirect lobbying governance related to climate change. The evidence suggests limited governance disclosure focused on oversight but lacks clarity on how lobbying activities are reviewed, managed, or aligned with climate goals. View Sources	D

Overall Assessment

Analysis

Score

Limited

Franklin Resources Inc. discloses that its Sustainability and Stewardship Council oversees the approaches of its investment managers to ensure consistency in engagement with its climate goals, stating that the council "is able to oversee the approaches by each of our investment managers to ensure consistency in engagement with our climate goals." Additionally, the firm highlights that the Stewardship and Sustainability Council and the Global Sustainability Strategy Team have identified climate change as a key strategic priority and are collaborating with internal stakeholders and clients to implement this agenda. However, the company does not provide detailed information about specific processes, mechanisms, or monitoring frameworks for lobbying alignment, nor does it explicitly address direct or indirect lobbying governance related to climate change. The evidence suggests limited governance disclosure focused on oversight but lacks clarity on how lobbying activities are reviewed, managed, or aligned with climate goals.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Franklin Resources discloses its engagement on two key climate-related rules—the “SEC Proposed Rule on Climate Related Disclosures” and the “SEC Fund Names Rule”—demonstrating transparency on which policies it targeted. It explains that it “responded directly as well as via industry bodies to regional consultations” and “attended meetings in which regulators are present,” including explicit “engagement with the SEC,” clarifying both its mechanisms and primary target. In terms of outcomes, the company expresses support for climate-related disclosures and the “hardwiring of sustainability into capital markets,” and notes engagement “to the extent that relevant regulatory organizations are proposing new regulations,” but it does not specify particular policy amendments or measurable goals it aimed to achieve through those interactions.	C