StepStone Group Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	StepStone discloses that climate-related advocacy is covered by its responsible-investment governance, stating that “StepStone’s Responsible Investment governance structure provides oversight of any engagement or public position to ensure alignment with the values of the Firm and the objectives as stated in its Responsible Investment Policy.” Oversight responsibility is clearly assigned: “The Climate Policy…is under the purview of the Responsible Investment Committee, which is governed by a charter approved by the StepStone Board of Directors,” and the committee “includes three members of the Board of Directors of StepStone Group Inc.” This committee is chaired by the “Global Head of Responsible Investment” and reports to the Board, while “StepStone’s executive team regularly updates the StepStone Board of Directors on responsible investments matters, including climate change considerations,” indicating a recurring review mechanism. The company also notes that it “looks to…engage directly with policymakers through consultation processes” and participates in numerous industry working groups, suggesting coverage of both direct engagement and indirect influence channels. However, the disclosures stop short of describing in detail how lobbying positions are assessed for climate alignment, how trade-association positions are reviewed, or what corrective actions are taken when misalignment is identified; the statement of “oversight” is high-level and no specific monitoring procedure or public audit of lobbying activities is provided. Therefore, while the presence of a named governance body and an annual policy review indicates moderate lobbying-governance transparency, the company does not disclose a detailed process for evaluating alignment across all lobbying channels or the outcomes of such reviews. View Sources	C

Overall Assessment

Analysis

Score

Moderate

StepStone discloses that climate-related advocacy is covered by its responsible-investment governance, stating that “StepStone’s Responsible Investment governance structure provides oversight of any engagement or public position to ensure alignment with the values of the Firm and the objectives as stated in its Responsible Investment Policy.” Oversight responsibility is clearly assigned: “The Climate Policy…is under the purview of the Responsible Investment Committee, which is governed by a charter approved by the StepStone Board of Directors,” and the committee “includes three members of the Board of Directors of StepStone Group Inc.” This committee is chaired by the “Global Head of Responsible Investment” and reports to the Board, while “StepStone’s executive team regularly updates the StepStone Board of Directors on responsible investments matters, including climate change considerations,” indicating a recurring review mechanism. The company also notes that it “looks to…engage directly with policymakers through consultation processes” and participates in numerous industry working groups, suggesting coverage of both direct engagement and indirect influence channels. However, the disclosures stop short of describing in detail how lobbying positions are assessed for climate alignment, how trade-association positions are reviewed, or what corrective actions are taken when misalignment is identified; the statement of “oversight” is high-level and no specific monitoring procedure or public audit of lobbying activities is provided. Therefore, while the presence of a named governance body and an annual policy review indicates moderate lobbying-governance transparency, the company does not disclose a detailed process for evaluating alignment across all lobbying channels or the outcomes of such reviews.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	StepStone Group offers a moderate level of transparency on its climate-related lobbying. It explicitly links its advocacy to three identifiable EU regulatory files—the EU Taxonomy Regulation, the Non-Financial Reporting Directive (NFRD) and the Sustainable Finance Disclosure Regulation (SFDR)—demonstrating clarity on which policies it engages. The firm also describes several channels it uses to influence those files, including participation in PRI and Invest Europe working groups, submitting formal letters of support or feedback, and taking part in public consultation processes, and notes that these activities put it in direct contact with EU policymakers. However, its disclosures stop short of stating the precise legislative changes it is backing or opposing; instead it refers only to broad aims such as encouraging alignment with Paris-aligned frameworks and wider adoption of TCFD reporting. Without concrete, measurable positions or desired amendments, the specific outcomes the firm seeks remain largely undefined.	C