IGM Financial Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	IGM Financial has established structured oversight of its public policy engagements to align with its climate commitments, although it does not disclose a dedicated climate-lobbying audit. According to the company, "Our processes to ensure engagement activities are consistent with our climate change strategy are governed by our IGM Executive Sustainability Committee, comprised of our senior executives from across IGM and its subsidiaries, and the Mackenzie Sustainability Committee which is led by Mackenzie’s Head of Sustainable Investing and includes senior leaders from across Mackenzie and IGM." These bodies "provide oversight to ensure that all direct and indirect public policy activities related to the environment are consistent with our internal policies, strategies and procedures, including IGM’s climate position and commitments, and Mackenzie’s climate action plan," and they "review and/or approve ESG-related policies, commitments, disclosures or positions and strategies." The company also notes that "The Lobbying Policy establishes a framework for compliance with lobbying legal requirements and outlines employee and Board activity and approval processes" and affirms "Yes" to conducting engagement activities "in line with the goals of the Paris Agreement." This indicates robust governance with clear formal ownership and mechanisms addressing both direct and indirect lobbying channels, but we found no evidence of a publicly available climate-lobbying alignment report or any process for engaging with or exiting trade associations whose positions conflict with its climate objectives. View Sources	B

Overall Assessment

Analysis

Score

Strong

IGM Financial has established structured oversight of its public policy engagements to align with its climate commitments, although it does not disclose a dedicated climate-lobbying audit. According to the company, "Our processes to ensure engagement activities are consistent with our climate change strategy are governed by our IGM Executive Sustainability Committee, comprised of our senior executives from across IGM and its subsidiaries, and the Mackenzie Sustainability Committee which is led by Mackenzie’s Head of Sustainable Investing and includes senior leaders from across Mackenzie and IGM." These bodies "provide oversight to ensure that all direct and indirect public policy activities related to the environment are consistent with our internal policies, strategies and procedures, including IGM’s climate position and commitments, and Mackenzie’s climate action plan," and they "review and/or approve ESG-related policies, commitments, disclosures or positions and strategies." The company also notes that "The Lobbying Policy establishes a framework for compliance with lobbying legal requirements and outlines employee and Board activity and approval processes" and affirms "Yes" to conducting engagement activities "in line with the goals of the Paris Agreement." This indicates robust governance with clear formal ownership and mechanisms addressing both direct and indirect lobbying channels, but we found no evidence of a publicly available climate-lobbying alignment report or any process for engaging with or exiting trade associations whose positions conflict with its climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	IGM Financial provides a moderate level of transparency on its climate-policy lobbying. It names two identifiable policy processes it engaged on—the U.S. Securities and Exchange Commission’s proposed climate-related disclosure rule and the International Sustainability Standards Board’s climate-disclosure standard—demonstrating that its dialogue goes beyond broad support for the Paris Agreement. The company also discloses the mechanisms it used, noting that it "submitted a consultation response in support of the Securities and Exchange Commission on Climate-related disclosures" and "submitted a consultation response in support of the ISSB consultation on Climate Disclosures," thereby specifying both the action taken (formal comment letters) and the policymaking targets (the SEC and the ISSB). Finally, it is explicit about the outcomes it seeks, stating its "support with no exceptions" for integrating the TCFD recommendations into the SEC rule and voicing unqualified backing for the ISSB standard, and it links these positions to alignment with the Paris Agreement. While the company does not reference additional climate policies or a wider range of lobbying channels, it is clear and specific on the two disclosure-focused initiatives it supports and the results it wants to see, offering a solid but not exhaustive picture of its climate-related lobbying activity.	C