KeyCorp

In 2022, decisions on activities that might influence policy related to climate change were made by management and Key's Executive Leadership Team and in Key's Corporate Responsibility Council. Positions are reviewed by Government Relations and our Corporate Responsibility team to confirm they remain consistent with Key's overall climate change strategy. Key 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.

Key's success at managing climate change risks and opportunities depends on effectively integrating climate change into our existing end-to-end governance structure, from our Board of Directors to our lines of business. Our Board serves as a foundation for the company's ability to manage climate-related risks and opportunities, as it oversees Key's policies and practices on significant issues of corporate responsibility, including corporate responsibility and sustainability. The Board provides consideration and counsel on environmental initiatives and strategies and oversees management's work to implement these goals. The Board is focused on and dedicated to ensuring Key operates in a manner aligned with shareholder expectations. Attention to climate-related issues is embedded in the Board's broader supervision through its committee structure. Climate risk and opportunity governance The table below depicts our climate risk management hierarchy. Board- or management-level committees with responsibility for climate-related issues. Not all management-level committees are depicted. Our Nominating & Corporate Governance Committee oversees climate strategy, while the Risk Committee has oversight of and accountability for climate risk. The Audit Committee considers climate-related issues through its oversight of the integrity of KeyCorp's financial statements, including reviewing disclosures made in our SEC filings. All committees report to the full Board and continue to incorporate additional insights from climate risk analysis into ongoing monitoring, governance, and strategy refinement. [...] Key's Climate Risk Team was established as a unique function within Risk Management and is responsible for integrating climate risk into all elements of the Framework. Our ERM risk taxonomy has been updated to include climate risk considerations across all risk types. Furthermore, tools like scenario analysis and scorecards will be utilized throughout the life cycle of a transaction to enable the identification and management of credit risk manifesting from physical and transition risks. One of the tools used to identify and assess risk is the Risk and Control Self-Assessment (RCSA), through which risks and the effectiveness of controls are assessed utilizing multiple sources of information. It provides a framework for lines of businesses at Key to identify and analyze climate-based risks and to provide guidelines for defining, identifying, assessing, and controlling for climate risks. [...] The Culture and Reputation Risk Committee serves as the governance body providing oversight of risks related to risk culture, conduct, ethics, corporate responsibility, climate, Key's brand, and reputation. In addition, the Culture and Reputation Risk Committee is the Approving Body of the program that oversees, reviews, modifies, and recommends for approval policies and programs related to corporate responsibility matters, including climate risk. The Climate Oversight Council is an advisory committee that provides high-level oversight of project progress, advice, and tracks outputs to ensure key milestones are met. Key's governance of climate risk is led by the Climate Risk Team, which is responsible for overseeing and guiding all climate risk-related activities. The ESG Working Group and Climate Risk Team communicate regarding matters related to strategy, decarbonization commitments, and sustainable financing.

Another notable update is the formation of a Climate Oversight Council (COC). This advisory body is overseeing Key's climate risk framework build-out. The COC provides high-level oversight of the project's progress and tracks outputs to ensure key milestones are met. [...] The Nominating and Corporate Governance Committee of the Board oversees climate strategy while the Risk Committee has oversight of and accountability for climate risk. The Audit Committee considers climate-related issues through its oversight of the integrity of KeyCorp's financial statements, including reviewing disclosures made in our SEC filings. All committees report to the full Board. [...] Climate risk responsibility is distributed across Key's Executive Leadership Team, including the Chief Financial Officer, the Chief Risk Officer, the General Counsel, and the Director of Corporate Center. Progress toward Key's sustainability commitments is driven by efforts throughout the company. Our ESG Working Group and Climate Oversight Council prioritize and make climate-related investment decisions and provide oversight of climate-related projects. The Culture and Reputation Risk Committee (CRRC), chaired by the CEO, serves as the governance body providing oversight of risks related to risk culture, conduct, ethics, ESG, climate, brand, and reputation. The CRRC is the approving body of the Climate Risk Program that oversees, reviews, modifies, and recommends policies and programs related to ESG matters, including climate risk, for approval.

Another notable update is the formation of a Climate Oversight Council (COC). This advisory body is overseeing Key's climate risk framework build-out. The COC provides high-level oversight of the project's progress and tracks outputs to ensure key milestones are met. [...] The Nominating and Corporate Governance Committee of the Board oversees climate strategy while the Risk Committee has oversight of and accountability for climate risk. The Audit Committee considers climate-related issues through its oversight of the integrity of KeyCorp's financial statements, including reviewing disclosures made in our SEC filings. All committees report to the full Board. [...] Climate risk responsibility is distributed across Key's Executive Leadership Team, including the Chief Financial Officer, the Chief Risk Officer, the General Counsel, and the Director of Corporate Center. Progress toward Key's sustainability commitments is driven by efforts throughout the company. Our ESG Working Group and Climate Oversight Council prioritize and make climate-related investment decisions and provide oversight of climate-related projects. The Culture and Reputation Risk Committee (CRRC), chaired by the CEO, serves as the governance body providing oversight of risks related to risk culture, conduct, ethics, ESG, climate, brand, and reputation. The CRRC is the approving body of the Climate Risk Program that oversees, reviews, modifies, and recommends policies and programs related to ESG matters, including climate risk, for approval.

In 2021, decisions on activities that might influence policy related to climate change were made by management and Key's Executive Leadership Team and in Key's Corporate Responsibility Council. Positions are reviewed by Government Relations and our Corporate Responsibility Group to confirm they remain consistent with Key's overall climate change strategy. Key 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.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]In 2021, decisions on activities that might influence policy related to climate change were made by management and Key's Executive Leadership Team and in Key's Corporate Responsibility Council. Positions are reviewed by Government Relations and our Corporate Responsibility Group to confirm they remain consistent with Key's overall climate change strategy. Key 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.