Lumen Technologies Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Lumen's disclosures outline a defined governance process for ensuring that its policy engagement aligns with its overall climate strategy, with specific mechanisms for oversight and alignment. The company explains that "involvement in organizations such as trade associations is assessed prior to active participation" and that "Lumen's Public Policy Group is also engaged if changes or new initiatives may have an impact on regulatory or public policy for the Company," demonstrating active management of both indirect and direct lobbying channels. Oversight responsibility is clearly attributed to the "Senior Vice President, Public Policy and Government Affairs," who "reports directly to Lumen's Executive Vice President, General Counsel & Secretary," and it notes that public policy updates and periodic reviews of its political strategy are provided to the Board of Directors and the Nominating and Corporate Governance Committee. The Sustainability Management Committee further supports consistency by "designing and overseeing our companywide sustainability program, including cybersecurity and data privacy, business ethics, network reliability, and climate change" and by consulting the Chief Compliance Officer and General Counsel as needed. Nonetheless, the company does not disclose a dedicated review or report evaluating the specific alignment of its lobbying activities with its climate goals, and in response to whether it has a Paris Agreement commitment, it states "No, and we do not plan to have one in the next two years," indicating that formal climate-focused auditing and commitment are not currently part of its lobbying governance framework. View Sources	3

Overall Assessment

Analysis

Score

Strong

Lumen's disclosures outline a defined governance process for ensuring that its policy engagement aligns with its overall climate strategy, with specific mechanisms for oversight and alignment. The company explains that "involvement in organizations such as trade associations is assessed prior to active participation" and that "Lumen's Public Policy Group is also engaged if changes or new initiatives may have an impact on regulatory or public policy for the Company," demonstrating active management of both indirect and direct lobbying channels. Oversight responsibility is clearly attributed to the "Senior Vice President, Public Policy and Government Affairs," who "reports directly to Lumen's Executive Vice President, General Counsel & Secretary," and it notes that public policy updates and periodic reviews of its political strategy are provided to the Board of Directors and the Nominating and Corporate Governance Committee. The Sustainability Management Committee further supports consistency by "designing and overseeing our companywide sustainability program, including cybersecurity and data privacy, business ethics, network reliability, and climate change" and by consulting the Chief Compliance Officer and General Counsel as needed. Nonetheless, the company does not disclose a dedicated review or report evaluating the specific alignment of its lobbying activities with its climate goals, and in response to whether it has a Paris Agreement commitment, it states "No, and we do not plan to have one in the next two years," indicating that formal climate-focused auditing and commitment are not currently part of its lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Lumen Technologies provides a moderate level of transparency on its climate-policy lobbying. It identifies two distinct pieces of legislation it has engaged on—the Green Communications Act to Promote Network Resiliency and Energy Efficiency in Communications Networks and the U.S. Securities and Exchange Commission’s proposed rule “The Enhancement and Standardization of Climate-Related Disclosures for Investors” (File No. S7-10-22)—giving readers a clear understanding of the specific policy arenas where it is active. The company describes one concrete mechanism and target for its advocacy, noting that it submitted comments to the SEC during the rule-making process through the U.S. Council on International Business; however, references to work carried out through the Global Enabling Sustainability Initiative are more general and do not name the government bodies approached, so the overall description of channels and audiences remains limited. On desired outcomes, the disclosure is detailed: Lumen asks the SEC to create “a level playing field for disclosures of Scope 3 GHG emissions,” to provide “clearer definitions for determining climate-related financial impacts,” and to grant “more flexibility on timelines and phase-in periods for new requirements,” demonstrating a clear set of policy changes it is pursuing. Taken together, the company offers solid insight into the substance of its lobbying and the changes it seeks, while leaving some gaps in how, and with whom, its broader advocacy is conducted.	2