Broadridge Financial Solutions Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Broadridge states that senior management and its cross-functional ESG Committee “monitor climate-related regulations and governance of climate change, including best practices… and assess whether engagement is necessary to ensure they are consistent with our continually developing climate strategy and goals,” showing a concrete mechanism to align external advocacy with climate objectives. Oversight is anchored at board level, as “Our Board of Directors and the Governance and Nominating Committee of our Board oversee Broadridge’s ongoing commitment to environmental, social and governance matters,” while “our management-led ESG Committee regularly reports to the Governance and Nominating Committee and annually to the full Board on ESG matters,” identifying named bodies responsible for review. The company also references direct climate-policy engagement, noting that “Broadridge has been engaging with the SEC… on climate policy… Broadridge's Chief Legal Officer is a member of the Working Group on Securities Disclosure Authority,” and it has a “public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the evidence does not disclose any systematic review of lobbying across trade associations, nor a formal escalation or exit policy for misaligned groups, and no dedicated lobbying-alignment report is published. Thus, while board-level accountability and a high-level monitoring process are in place, the governance framework for both direct and indirect climate lobbying remains only partially described, indicating moderate strength. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Broadridge states that senior management and its cross-functional ESG Committee “monitor climate-related regulations and governance of climate change, including best practices… and assess whether engagement is necessary to ensure they are consistent with our continually developing climate strategy and goals,” showing a concrete mechanism to align external advocacy with climate objectives. Oversight is anchored at board level, as “Our Board of Directors and the Governance and Nominating Committee of our Board oversee Broadridge’s ongoing commitment to environmental, social and governance matters,” while “our management-led ESG Committee regularly reports to the Governance and Nominating Committee and annually to the full Board on ESG matters,” identifying named bodies responsible for review. The company also references direct climate-policy engagement, noting that “Broadridge has been engaging with the SEC… on climate policy… Broadridge's Chief Legal Officer is a member of the Working Group on Securities Disclosure Authority,” and it has a “public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the evidence does not disclose any systematic review of lobbying across trade associations, nor a formal escalation or exit policy for misaligned groups, and no dedicated lobbying-alignment report is published. Thus, while board-level accountability and a high-level monitoring process are in place, the governance framework for both direct and indirect climate lobbying remains only partially described, indicating moderate strength.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Broadridge provides a fair amount of detail about its climate-related public-policy engagement. It explicitly names one concrete initiative it has lobbied on—the “SEC’s proposed climate disclosure rule” in the United States—showing some, though not extensive, specificity around the policies it targets. The company is considerably more transparent about how it engages: the disclosures note that “Broadridge’s Chief Legal Officer participates in meetings with the SEC and SEC Commissioners to express views on climate change disclosures,” that he sits on the Working Group on Securities Disclosure Authority, and that the group “submitted comments on climate-related disclosures for investors” to the SEC, with a public link to the letter. These references cover multiple mechanisms (meetings, working-group participation, formal comment letters) and name a clear policymaking target (the SEC and individual Commissioners). Broadridge also spells out the result it is seeking, stating that it supports the SEC rule “with minor exceptions” and has offered “alternative approaches” in its June 16 2022 comment letter, indicating a well-defined position and desired modifications. Taken together, the disclosures show moderate transparency—strong on mechanisms and intentions, but limited to a single identified policy.	C