Truist Financial Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Truist Financial Corp demonstrates a robust climate lobbying governance framework that aligns its direct and indirect advocacy with its Net Zero by 2050 target through structured monitoring, executive and board oversight, and dedicated climate disclosures. The company "reviews and assesses alignment of Truist’s external relationships with our Net Zero by 2050 goal" and has published a "2023 Climate Lobbying Report" to provide transparency. Internally, the Government Affairs, Corporate Communications, and Corporate Responsibility teams "conduct regular monitoring of our major trade associations’ public statements and regulatory comments, including those on climate change," using a "monitoring framework" informed by the Interfaith Center on Corporate Responsibility and the Ceres Company Network and integrated into its TCFD reporting. Oversight is led by the public affairs team, which "reports directly to Truist’s chief legal officer and head of public affairs, who is a direct report to the chief executive officer," while "Executive Leadership annually reviews Truist’s Statement of Political Engagement and receives reports that provide information on our trade association memberships, disbursements from Truist-sponsored PACs, contributions to any ballot measure committee, and lobbying activity." Additionally, the Nominating and Governance Committee of the Board "receives an annual review of the funding, governance, advocacy initiatives, and political contribution activities" of PACs and trade associations, and any reputational concerns are escalated through an "established process for reputational risk escalation" to the Ethics, Business Practices, and Conduct Committee on a quarterly basis. This comprehensive structure indicates strong governance of both direct lobbying and trade association engagement, although the company does not disclose specific corrective actions such as withdrawing from misaligned associations beyond its escalation protocols. View Sources	4

Overall Assessment

Analysis

Score

Comprehensive

Truist Financial Corp demonstrates a robust climate lobbying governance framework that aligns its direct and indirect advocacy with its Net Zero by 2050 target through structured monitoring, executive and board oversight, and dedicated climate disclosures. The company "reviews and assesses alignment of Truist’s external relationships with our Net Zero by 2050 goal" and has published a "2023 Climate Lobbying Report" to provide transparency. Internally, the Government Affairs, Corporate Communications, and Corporate Responsibility teams "conduct regular monitoring of our major trade associations’ public statements and regulatory comments, including those on climate change," using a "monitoring framework" informed by the Interfaith Center on Corporate Responsibility and the Ceres Company Network and integrated into its TCFD reporting. Oversight is led by the public affairs team, which "reports directly to Truist’s chief legal officer and head of public affairs, who is a direct report to the chief executive officer," while "Executive Leadership annually reviews Truist’s Statement of Political Engagement and receives reports that provide information on our trade association memberships, disbursements from Truist-sponsored PACs, contributions to any ballot measure committee, and lobbying activity." Additionally, the Nominating and Governance Committee of the Board "receives an annual review of the funding, governance, advocacy initiatives, and political contribution activities" of PACs and trade associations, and any reputational concerns are escalated through an "established process for reputational risk escalation" to the Ethics, Business Practices, and Conduct Committee on a quarterly basis. This comprehensive structure indicates strong governance of both direct lobbying and trade association engagement, although the company does not disclose specific corrective actions such as withdrawing from misaligned associations beyond its escalation protocols.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Truist Financial offers a high level of transparency on where and how it engages on climate-related policy. The company names multiple concrete policy arenas, including the SEC’s proposed climate disclosure rule, new climate disclosure requirements passed by the California State Assembly, draft standards from the International Sustainability Standards Board, the Paris Climate Agreement, and climate provisions in the Inflation Reduction Act, demonstrating clear disclosure of the measures it is tracking and influencing. It also explains the channels it uses: the bank “employs in-house and outside registered lobbyists who engage directly with elected officials, regulatory organizations, and trade associations,” supplements this with indirect work through bodies such as the American Bankers Association and the Business Roundtable, and even runs structured surveys of those associations to test alignment—showing direct lobbying, association-based lobbying and internal review as three distinct mechanisms. Specific targets are identified, among them the SEC, the California legislature and the ISSB, indicating who receives the lobbying effort. Where Truist is less forthcoming is on the precise policy outcomes it seeks. Beyond general statements about supporting “important climate measures, including the Paris Agreement,” alignment with its net-zero ambitions and a preference for “consistent global disclosure frameworks,” the disclosures stop short of articulating concrete legislative changes, quantitative thresholds or amendments it is advocating. Overall, the company provides strong visibility into the policies and channels of engagement, but only broad indications of the outcomes it hopes to secure.	3