Direct Lobbying Transparency
| Overall Assessment | Comment | Score |
|---|---|---|
| Comprehensive | Sun Life Financial provides a very detailed picture of its climate-policy engagement. It names multiple specific measures it has worked on, including the federal government’s “Green Building Strategy,” OSFI’s draft “Guideline B-15: Climate Risk Management,” the SEC’s proposed “Rules to Enhance and Standardize Climate-Related Disclosures for Investors,” Canada’s “Net-Zero Challenge,” the Canadian Securities Administrators’ proposed “National Instrument 51-107,” and the U.S. NAIC “Climate Risk Disclosure Survey,” among others. The company is equally explicit about how it engages: it describes “responding to consultations and engaging with policymakers and securities regulators individually and/or through industry associations,” “submitt[ing] both high-level and detailed comments on the draft guideline,” “meet[ing] with Environment and Climate Change Canada policy staff multiple times,” “contribut[ing] to the ACLI’s remarks,” and raising recommendations in “individual and trade association-led meetings with federal officials,” thereby revealing both direct and indirect mechanisms and naming concrete targets such as OSFI, the SEC, NAIC, Environment and Climate Change Canada, the Canadian Securities Administrators, the Bermuda Monetary Authority and the Monetary Authority of Singapore. Finally, it is clear about what it seeks to achieve: it has “recommended delaying implementation to align with forthcoming climate disclosure standards,” “requested leniency on some requirements due to methodological and data availability constraints,” called for “mandatory economy-wide climate-related financial reporting” while asking for flexibility on Scope 3 and scenario analysis, and pressed for “closer alignment with emerging climate transition plan best practices.” These specific, outcome-oriented positions, coupled with statements of “support with minor exceptions” or “support with no exceptions” and confirmation that the engagements are “aligned with the Paris Agreement,” demonstrate a high level of transparency across all aspects of its climate-related lobbying. | 4 |