First Capital Real Estate Investment Trust – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	First Capital REIT discloses some oversight for climate-related external engagement yet provides little detail that is specific to lobbying activities. The company states that "the Senior Director, ESG communicates with the senior management and executive leadership teams … [and] is engaged to assist with preparing a response or speaking notes, ensuring alignment with our strategy" and similarly that "the VP, ESG … is engaged to assist with preparing a response or speaking notes, ensuring alignment with our strategy." It also confirms that it has "a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” These statements indicate a limited process and named individuals who review climate-related external communications for consistency with the firm’s climate strategy, which signals some governance of advocacy activities. However, the disclosures do not describe how lobbying—either direct contact with policymakers or indirect lobbying through trade associations—is monitored, audited, or corrected, and there is no information on Board involvement, escalation procedures, or decisions to engage or withdraw from misaligned industry bodies. Consequently, while there is evidence of a basic alignment check for public climate engagement, the company does not disclose a broader governance framework that systematically oversees or manages climate lobbying activities. View Sources	D

Overall Assessment

Analysis

Score

Limited

First Capital REIT discloses some oversight for climate-related external engagement yet provides little detail that is specific to lobbying activities. The company states that "the Senior Director, ESG communicates with the senior management and executive leadership teams … [and] is engaged to assist with preparing a response or speaking notes, ensuring alignment with our strategy" and similarly that "the VP, ESG … is engaged to assist with preparing a response or speaking notes, ensuring alignment with our strategy." It also confirms that it has "a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” These statements indicate a limited process and named individuals who review climate-related external communications for consistency with the firm’s climate strategy, which signals some governance of advocacy activities. However, the disclosures do not describe how lobbying—either direct contact with policymakers or indirect lobbying through trade associations—is monitored, audited, or corrected, and there is no information on Board involvement, escalation procedures, or decisions to engage or withdraw from misaligned industry bodies. Consequently, while there is evidence of a basic alignment check for public climate engagement, the company does not disclose a broader governance framework that systematically oversees or manages climate lobbying activities.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	First Capital Real Estate Investment Trust provides very limited transparency around its climate lobbying. It mentions "connecting with and informing regulators" and engaging "regulators, city planners and permitting bodies" but does not disclose any specific direct or indirect lobbying mechanisms or identify policymakers or agencies targeted. The company names no particular climate policies, laws, or regulations it has lobbied, and while it asserts that "regulations can rapidly speed up decarbonization in buildings," it does not spell out any specific regulatory amendments or legislative goals it seeks. Overall, the firm's disclosures focus on general collaboration and industry discussion rather than explicit policy engagement or defined policy outcomes.	D