Visa Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Visa has established a robust governance framework for its political engagement, with clear oversight by its Board’s Nominating and Corporate Governance Committee and implementation by its Global Government Engagement Department. The Policy states that “the Board of Directors of Visa, acting through the Committee, is responsible for overseeing the Company’s lobbying activities and political contributions,” while Government Engagement “is responsible for implementing the Policy, developing and maintaining procedures to support the Policy, monitoring the operation and effectiveness of the Policy, and ensuring that Company directors, officers and employees receive adequate communication and training regarding the Policy.” Visa requires Government Engagement to “pre-approve the Company’s retention of outside lobbyists,” “supervise the Company’s attempts to influence government actions,” and “oversee the Company’s compliance with applicable registration, reporting and other laws governing lobbying activity.” The company also mandates an annual report to the Committee on “the Company’s lobbying and advocacy related expenditures,” including details on trade and tax-exempt association payments, and publicly discloses U.S. trade-association membership names and aggregate lobbying spend. Management further reviews “the continued appropriateness of maintaining these memberships at least annually, including by taking into consideration the public positions on differing policy issues taken by these associations.” However, we found no evidence of a policy or process that explicitly aligns Visa’s lobbying activities with its climate strategy, such as a dedicated review of climate-related lobbying efforts, exit or engagement criteria for trade associations on climate issues, or a climate-lobbying audit overseen by a named individual or committee. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Visa has established a robust governance framework for its political engagement, with clear oversight by its Board’s Nominating and Corporate Governance Committee and implementation by its Global Government Engagement Department. The Policy states that “the Board of Directors of Visa, acting through the Committee, is responsible for overseeing the Company’s lobbying activities and political contributions,” while Government Engagement “is responsible for implementing the Policy, developing and maintaining procedures to support the Policy, monitoring the operation and effectiveness of the Policy, and ensuring that Company directors, officers and employees receive adequate communication and training regarding the Policy.” Visa requires Government Engagement to “pre-approve the Company’s retention of outside lobbyists,” “supervise the Company’s attempts to influence government actions,” and “oversee the Company’s compliance with applicable registration, reporting and other laws governing lobbying activity.” The company also mandates an annual report to the Committee on “the Company’s lobbying and advocacy related expenditures,” including details on trade and tax-exempt association payments, and publicly discloses U.S. trade-association membership names and aggregate lobbying spend. Management further reviews “the continued appropriateness of maintaining these memberships at least annually, including by taking into consideration the public positions on differing policy issues taken by these associations.” However, we found no evidence of a policy or process that explicitly aligns Visa’s lobbying activities with its climate strategy, such as a dedicated review of climate-related lobbying efforts, exit or engagement criteria for trade associations on climate issues, or a climate-lobbying audit overseen by a named individual or committee.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Visa provides only high-level descriptions of its climate-related advocacy. The company indicates that it “engages with governments, policymakers and stakeholders globally” and that it participates in trade and business associations such as the U.S. Chamber of Commerce, the Business Roundtable and the World Economic Forum, but it does not name any specific climate laws, regulations or rulemakings it has tried to influence, nor does it identify the jurisdictions or officials it contacts. Its description of mechanisms is limited to general references to membership in working groups and committees; there is no detail on whether it submits letters, holds meetings or gives testimony, and no policymaking targets are specified. The outcomes sought are expressed only in broad terms—support for “market-based solutions,” “sustainable commerce,” or “net-zero solutions”—without translating these aspirations into concrete legislative or regulatory objectives. Because the disclosure remains general across all three areas, Visa’s transparency on its climate-policy lobbying is limited.	D