SL Green Realty Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	SL Green has established a process to align its policy engagement with its climate strategy by using scenario-based risk assessment, noting that it “quantitatively assess[s] transition risks from carbon pricing under IPCC RCP 2.6, a 1.5°C-aligned global emission scenario” and uses the results “to guide our engagement with outside organizations such as ULI, Urban Green Council, Mayor’s Office of Sustainability, REBNY, and BOMA,” demonstrating a concrete mechanism for ensuring its direct engagement aligns with its climate goals. The company also emphasizes that it “actively engages with both governmental and non-governmental organizations (NGOs) and industry peers to raise awareness and address environmental issues,” indicating an active approach to policy engagement. However, the company does not disclose a named individual or committee that oversees or reviews these engagement activities, nor does it outline any formal monitoring, management, or enforcement procedures beyond the scenario analysis. We also found no evidence of policies addressing indirect lobbying through trade associations or of processes to correct or exit from associations whose positions diverge from its climate objectives. View Sources	C

Overall Assessment

Analysis

Score

Moderate

SL Green has established a process to align its policy engagement with its climate strategy by using scenario-based risk assessment, noting that it “quantitatively assess[s] transition risks from carbon pricing under IPCC RCP 2.6, a 1.5°C-aligned global emission scenario” and uses the results “to guide our engagement with outside organizations such as ULI, Urban Green Council, Mayor’s Office of Sustainability, REBNY, and BOMA,” demonstrating a concrete mechanism for ensuring its direct engagement aligns with its climate goals. The company also emphasizes that it “actively engages with both governmental and non-governmental organizations (NGOs) and industry peers to raise awareness and address environmental issues,” indicating an active approach to policy engagement. However, the company does not disclose a named individual or committee that oversees or reviews these engagement activities, nor does it outline any formal monitoring, management, or enforcement procedures beyond the scenario analysis. We also found no evidence of policies addressing indirect lobbying through trade associations or of processes to correct or exit from associations whose positions diverge from its climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	SL Green Realty Corp. provides only limited transparency about its climate-related lobbying. It names one specific regulation it monitors—New York City’s Local Law 97 under the Climate Mobilization Act—and notes that “Our team evaluated the proposed rules published by the New York City Department of Buildings,” but it does not discuss any other climate policies it seeks to influence. The company indicates that it is “participating in industry committees to provide feedback on proposed rule-making,” yet it gives no detail on the form of that engagement—such as meetings, written submissions, or testimony—nor does it identify the government bodies or individual officials it approaches. Finally, the disclosures focus on the firm’s plan to comply with LL97 and the expected lack of “material financial impact,” without stating any policy changes or legislative outcomes it is advocating. Together, these elements reveal only a narrow glimpse of the company’s climate-policy advocacy efforts, with key information about mechanisms, targets, and desired outcomes absent.	D