Boston Properties Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Boston Properties discloses a limited but identifiable process that touches on how its external engagement relates to its climate strategy, yet it stops short of describing a dedicated governance framework for lobbying activities. The company states that “we have a Company-Wide Sustainability Operations Committee that tracks and discusses regional policies” and uses this forum to keep “engagement activities … consistent with your overall climate change strategy,” indicating some internal mechanism for checking policy advocacy against climate goals. Oversight of broader sustainability matters sits with a Board-level Sustainability Committee whose remit includes “periodically reviewing legal, regulatory, and compliance matters that may have a material impact on the implementation of the Company’s sustainability objectives,” suggesting that at least one Board committee is expected to look at regulatory or policy issues. However, the disclosures do not specify how direct or indirect lobbying positions are reviewed, do not mention any systematic assessment of trade-association alignment, and do not identify an individual or team formally responsible for approving or monitoring lobbying activities. The evidence centres on ESG performance reporting—“the Company organizes meetings, presentations, and regional Sustainability Summits to communicate the objectives and performance of our ESG initiatives”—rather than on concrete controls over lobbying conduct. Because the company provides only a general description of committees that track policy developments and no explicit lobbying-alignment policy, monitoring procedure, or trade-association review, the governance approach appears limited and largely implicit rather than formalised or comprehensive. View Sources	D

Overall Assessment

Analysis

Score

Limited

Boston Properties discloses a limited but identifiable process that touches on how its external engagement relates to its climate strategy, yet it stops short of describing a dedicated governance framework for lobbying activities. The company states that “we have a Company-Wide Sustainability Operations Committee that tracks and discusses regional policies” and uses this forum to keep “engagement activities … consistent with your overall climate change strategy,” indicating some internal mechanism for checking policy advocacy against climate goals. Oversight of broader sustainability matters sits with a Board-level Sustainability Committee whose remit includes “periodically reviewing legal, regulatory, and compliance matters that may have a material impact on the implementation of the Company’s sustainability objectives,” suggesting that at least one Board committee is expected to look at regulatory or policy issues. However, the disclosures do not specify how direct or indirect lobbying positions are reviewed, do not mention any systematic assessment of trade-association alignment, and do not identify an individual or team formally responsible for approving or monitoring lobbying activities. The evidence centres on ESG performance reporting—“the Company organizes meetings, presentations, and regional Sustainability Summits to communicate the objectives and performance of our ESG initiatives”—rather than on concrete controls over lobbying conduct. Because the company provides only a general description of committees that track policy developments and no explicit lobbying-alignment policy, monitoring procedure, or trade-association review, the governance approach appears limited and largely implicit rather than formalised or comprehensive.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Boston Properties offers transparent disclosure of the specific climate policies it lobbies, clearly naming “Building Energy Use Disclosure,” “Energy/Carbon Performance Standards,” “Building Codes,” and “Carbon taxes,” and indicating its engagement at the regional level in the United States. It reports that it works through industry associations—“ULI (Greenprint), BOMA, USGBC (National), USGBC (MA), A Better City and the Boston Green Ribbon Commission”—and “routinely works with policymakers in our local jurisdictions” to shape building energy and carbon regulations, but stops short of identifying the individual government bodies or specifying whether its input is delivered via meetings, letters, or formal submissions. The company also outlines its goals for influencing “building energy reporting ordinances, energy performance standards and fines,” “building carbon reporting ordinances, carbon performance standards/fines,” and assessing rules on “minimum ENERGY STAR scores, electrification requirements, and EV charging station infrastructure requirements,” as well as securing “RECs from ‘eligible sources.’” These outcomes demonstrate a clear intent to affect multiple regulatory elements, though the lack of quantifiable targets or detailed rationale for each position leaves the precise end goals somewhat open to interpretation.	C