MetLife Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	MetLife demonstrates a structured approach to ensuring its policy advocacy aligns with its climate strategy, with specified approval processes and departmental oversight. It maintains an “official climate change policy statement” accessible on its sustainability website and confirms that “our direct and indirect policy activities are consistent with this strategy,” reflecting active alignment of both direct and indirect lobbying. Before engaging with trade organizations, corporate pledges or other policy-related activities, “all MetLife employees must undergo the appropriate approval process, including vetting activity and subject matter with appropriate senior finance, risk or investment leadership,” illustrating a clear process for oversight of lobbying engagements. The Corporate Affairs department reinforces this governance through a suite of policies—such as the “public official interaction policy” and “corporate contributions policy”—to ensure that “all public MetLife messages and engagements will consistently and accurately reflect MetLife’s positions on a variety of topics, including climate change.” These communications, along with broader sustainability disclosures, are “closely reviewed by the Sustainability Team, in conjunction with a working group consisting of many departments and geographies, for consistency with MetLife’s climate strategy,” providing additional oversight and review. While these processes outline clear internal checkpoints and formal bodies responsible for governance, the company does not disclose a dedicated climate-lobbying audit or a specific board-level committee charged with reviewing climate-policy alignment. View Sources	B

Overall Assessment

Analysis

Score

Strong

MetLife demonstrates a structured approach to ensuring its policy advocacy aligns with its climate strategy, with specified approval processes and departmental oversight. It maintains an “official climate change policy statement” accessible on its sustainability website and confirms that “our direct and indirect policy activities are consistent with this strategy,” reflecting active alignment of both direct and indirect lobbying. Before engaging with trade organizations, corporate pledges or other policy-related activities, “all MetLife employees must undergo the appropriate approval process, including vetting activity and subject matter with appropriate senior finance, risk or investment leadership,” illustrating a clear process for oversight of lobbying engagements. The Corporate Affairs department reinforces this governance through a suite of policies—such as the “public official interaction policy” and “corporate contributions policy”—to ensure that “all public MetLife messages and engagements will consistently and accurately reflect MetLife’s positions on a variety of topics, including climate change.” These communications, along with broader sustainability disclosures, are “closely reviewed by the Sustainability Team, in conjunction with a working group consisting of many departments and geographies, for consistency with MetLife’s climate strategy,” providing additional oversight and review. While these processes outline clear internal checkpoints and formal bodies responsible for governance, the company does not disclose a dedicated climate-lobbying audit or a specific board-level committee charged with reviewing climate-policy alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	MetLife Inc. offers only limited transparency regarding its climate-related lobbying. The disclosures explain that MetLife Investment Management “engages with issuers, intermediaries, market participants, and policy makers” and that “Direct engagement with an issuer or company’s senior leadership is a fundamental part of our research process,” signalling that dialogue is one of its principal channels, yet no specific government departments, regulators, or legislative forums are named. Likewise, the company refers broadly to thematic work on Scope 3 greenhouse-gas emissions and to “new reporting requirements being introduced in places such as the EU, Japan, Australia and California,” but it does not identify any particular bill, rule-making, or regulatory docket it has tried to influence. The outcomes sought are expressed only in general terms—such as seeking “transparent public disclosures” and learning “how different issuers and borrowers are addressing Scope 3 reporting and data challenges”—without spelling out precise policy changes or positions. In sum, the company describes general areas of engagement and the methods it uses but stops short of detailing the exact policies, targets, or concrete legislative results it is pursuing.	D