KeyCorp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	KeyCorp discloses a defined process for keeping its policy engagement consistent with its climate objectives, noting that "decisions on activities that might influence policy related to climate change were made by management and Keys Executive Leadership Team and in Key's Corporate Responsibility Council" and that such positions "are reviewed by Government Relations and our Corporate Responsibility Group to confirm they remain consistent with Key's overall climate change strategy." This indicates that both direct and indirect engagements are subject to an internal alignment check, as the company "takes a measured approach in determining if and when the Bank should engage either directly or indirectly on policies at the local and federal level on all issues, including climate change." Oversight responsibility is assigned to senior-level bodies; the disclosure states that the Culture and Reputation Risk Committee, "chaired by the CEO, serves as the governance body providing oversight of risks related to risk culture, conduct, ethics, ESG, climate, brand, and reputation," while policy positions are escalated through the Executive Leadership Team and the Corporate Responsibility Council. However, the company does not disclose criteria for assessing or correcting misalignment of its trade-association lobbying, nor does it publish a dedicated lobbying-alignment report or audit, so the extent of monitoring beyond internal reviews and the mechanisms for addressing conflicts remain unclear. View Sources	C

Overall Assessment

Analysis

Score

Moderate

KeyCorp discloses a defined process for keeping its policy engagement consistent with its climate objectives, noting that "decisions on activities that might influence policy related to climate change were made by management and Keys Executive Leadership Team and in Key's Corporate Responsibility Council" and that such positions "are reviewed by Government Relations and our Corporate Responsibility Group to confirm they remain consistent with Key's overall climate change strategy." This indicates that both direct and indirect engagements are subject to an internal alignment check, as the company "takes a measured approach in determining if and when the Bank should engage either directly or indirectly on policies at the local and federal level on all issues, including climate change." Oversight responsibility is assigned to senior-level bodies; the disclosure states that the Culture and Reputation Risk Committee, "chaired by the CEO, serves as the governance body providing oversight of risks related to risk culture, conduct, ethics, ESG, climate, brand, and reputation," while policy positions are escalated through the Executive Leadership Team and the Corporate Responsibility Council. However, the company does not disclose criteria for assessing or correcting misalignment of its trade-association lobbying, nor does it publish a dedicated lobbying-alignment report or audit, so the extent of monitoring beyond internal reviews and the mechanisms for addressing conflicts remain unclear.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	KeyCorp provides only limited visibility into its climate-related lobbying. The company says it engages on climate issues with “regulators, public officials, and agencies” and that its Government Relations program relies on “in-house government relations professionals and contract lobbyists to advocate on our behalf,” and it notes indirect activity through trade associations such as ACORE, but it offers little detail on how these engagements are carried out or which specific officials are approached. The disclosures mention broad policy areas—climate change, affordable housing, the Community Reinvestment Act and OCC’s Project REACh—but do not identify any particular climate bill, regulation, or rule that the bank has tried to influence. Similarly, KeyCorp voices general support for “green initiatives” and for “legislation to support and expand accessible and affordable housing,” yet it does not spell out the concrete legislative amendments, targets, or regulatory changes it seeks. As a result, while the company acknowledges that it lobbies and outlines the basic channels it uses, it stops short of providing the detailed policy names, lobbying tactics, and specific outcomes that would demonstrate fuller transparency.	D