Truist Financial Corp

Lobbying Governance

AI Extracted Evidence Snippet Source

Review and assess alignment of Truist's external relationships with our Net Zero by 2050 goal. [...] To help our company understand and assess our external partners, Truist reviews its engagement with trade associations and lobbying organizations to assess how their positions affect our company, our stakeholders, and the policies that may affect our ability to achieve our Net Zero by 2050 goal. For more information, see our 2023 Climate Lobbying Report. [...] Accountability. [...] As Truist builds capacity and integrates climate risks and opportunities into our governance and strategy, we will continue to disclose our progress annually. For example, in 2024, we will publish this TCFD report, a Corporate Responsibility & Sustainability Report, a Disclosure Summary, and a Climate Lobbying Report. As disclosure frameworks continue to evolve, we will consider updates as appropriate.

https://ir.truist.com/image/Truist2023TCFD.pdf

## Management oversight of trade association relationships

As part of Truist's involvement in the public policy process, we regularly express our views on policy matters to elected officials and their staff, as well as the principals and staff of various regulatory organizations on core banking, business, and economic advocacy. To facilitate these efforts, Truist employs in-house and outside registered lobbyists who either engage directly with these officials, coordinate the engagement of relevant Truist subject matter experts with them, or work with trade associations and informal organizations engaged with such officials and organizations in the policymaking process.

The public affairs team reports directly to Truist's chief legal officer and head of public affairs, who is a direct report to the chief executive officer. Truist's 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. As part of its annual review, Executive Leadership provides oversight of large trade association memberships as well as political contributions and lobbying activities. Ensuring oversight, policies, and transparency around our public policy advocacy is a priority for Truist.

## Board oversight of trade association relationships

The Nominating and Governance Committee of Truist's Board of Directors oversees our policies and practices relating to political contributions and lobbying. As part of this oversight, the Committee receives an annual review of the funding, governance, advocacy initiatives, and political contribution activities of the Truist-sponsored political action committees and expenditures relating to our major trade associations.

## Compliance and monitoring

Truist is committed to complying with all applicable laws regarding political activity, including MSRB Rule G-37, SEC Rule 206(4)- 5, CFTC Rule 23.451, and applicable state and local laws and regulations. We have policies and procedures in place consistent with this commitment. Truist maintains compliance processes intended to ensure that our activities are conducted in accordance with those policies, our Code of Ethics, and with all relevant laws governing political contributions and lobbying activities.

Further, we have an established process for reputational risk escalation and will use this to address any concerns that arise from ongoing monitoring of trade association partnerships. The Ethics, Business Practices, and Conduct Committee (EBPCC) which reviews all reputational risk assessment activity on a quarterly basis, will receive any escalated concerns and will serve as the decision-making body for any changes or actions. We conduct regular monitoring of our major trade associations' public statements and regulatory comments, including those on climate change, through our Government Relations, Enterprise Ethics, ESG and Corporate Communications teams.

https://ir.truist.com/image/truist-climate-lobbying-summary.pdf

Truist's Government Affairs, Corporate Communications, and Corporate Responsibility teams collectively monitor major trade associations' public statements and activities related to the issues that are important to Truist, including climate and sustainability matters. With these reviews, we aim to understand whether trade association positions and activities align with important climate measures, including the Paris Agreement, and whether trade association partners support our Net Zero and related climate goals. When we developed our monitoring framework, we drew from outlines provided by the Interfaith Center on Corporate Responsibility (ICCR) and the Ceres Company Network and incorporated our current reporting under the TCFD framework. [...] The Government Affairs team reports directly to Truist's chief legal officer. Truist's senior leaders annually review Truist's Statement of Political Engagement and receive reports that provide information on our trade association memberships, disbursements from Truist-sponsored PACs, contributions to any ballot measure committee, and lobbying activity. As part of its annual review, senior leadership provides oversight of large trade association memberships as well as political contributions and lobbying activities. [...] The Nominating and Governance Committee of Truist's Board of Directors oversees our policies and practices relating to political contributions and lobbying. As part of this oversight, the committee receives an annual review of the funding, governance, advocacy initiatives, and political contribution activities of Truist-sponsored political action committees and our major trade associations.

https://ir.truist.com/image/Truist2023ClimateLobbyingSummary.pdf

###### Political engagement

Public policy has a significant impact on Truist's business operations as well as those of our stakeholders. Truist participates in policy discussions on issues that support our interests. We sponsor employee political action committees (PACs), which allow teammates, corporate directors, and PAC advisory board members to voluntarily pool their financial resources to support candidates who support legislation that's meaningful to us and our shareholders, clients, and communities. A detailed statement of political engagement and a list of 2022 PAC [activity can be found here.](https://ir.truist.com/corporate-social-responsibility)

- [Truist 2022 Statement of Political Engagement](https://ir.truist.com/download/Truist2022StatementOfPoliticalEngagement.pdf)

- [Truist 2022 Political Contributions](https://ir.truist.com/image/Truist2022PoliticalContributions.pdf)

https://www.truist.com/content/dam/truist-bank/us/en/documents/disclosures/non-lob/truist-2022-corporate-responsibility.pdf