Chubb Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Chubb Ltd provides a high level of transparency around its climate-policy lobbying. It identifies several concrete policy arenas it engages on, including reforms to the U.S. National Flood Insurance Program (NFIP), “approaches for improving the public-private crop insurance program for farmers within proposed farm legislation,” and state-led climate-disclosure requirements where it has supplied detailed responses to insurance regulators in California, Connecticut, Minnesota, New York, Washington and Pennsylvania, as well as to regulators in the U.K., EU, Australia and New Zealand. The company also lays out the channels it uses: direct legislative advocacy on Capitol Hill; indirect work “directly and through trade associations with legislators”; participation in the multi-stakeholder SmarterSafer Coalition; and formal submissions to multiple domestic and international insurance regulators—clearly naming the institutional targets such as Congress, the Federal Emergency Management Agency and specific state insurance departments. Chubb is equally explicit about what it wants those engagements to achieve, backing reforms that would “move NFIP to fiscal soundness by gradually phasing properties to risk-based rates, coupled with mitigation assistance and affordability measures for low-income property owners,” supporting permission for FEMA to buy reinsurance, seeking “solutions that maintain and improve upon the coverage against climate-related risks” in the crop insurance program and advocating a centralized methodology for collecting climate-risk data. By disclosing the specific policies, the means through which it advocates, the bodies it addresses and the detailed outcomes it pursues, Chubb demonstrates comprehensive transparency in its climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Strong Chubb has embedded climate alignment into its lobbying governance through a centralized Government Affairs function and senior oversight, with “Chubb has a government affairs function that coordinates with business units and the executive team on public policy and advocacy strategies” and “Chubb maintains a rigorous process to ensure that its direct and indirect activities to influence policy are consistent with the company’s strategy and objectives, including overall climate change strategy,” covering both direct and indirect advocacy. Oversight is anchored by the General Counsel, who “reports periodically to the Nominating and Governance Committee,” escalating new climate-related advocacy issues for board-level review and direction, and by the Executive Committee’s role in ensuring consistency with the company’s objectives. The board-approved “Climate Change Policy Statement” further embeds climate goals into its engagement approach. However, the company does not disclose the frequency or criteria for reviewing advocacy positions, there is no public audit of climate lobbying alignment, and we found no evidence of a formal process to assess or exit trade or industry associations whose policy views may conflict with Chubb’s climate commitments. 3