Bank of New York Mellon Corp/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	BNY Mellon operates a formal governance framework in which its Public Policy and Government Affairs team “reports to the General Counsel and is overseen by the Board of Directors Corporate Governance, Nominating and Social Responsibility (CGNSR) Committee” that “provides regular updates (at least semi-annually) to the CGNSR Committee to set engagement strategy, receive feedback and maintain alignment with business priorities.” This structure extends to its climate-related lobbying, as “formal communications with industry groups and policy makers are generally reviewed, approved and overseen by BNY Mellon’s Corporate Communications and Government Affairs groups” and key input from the “Enterprise ESG and sustainability groups” is sought to ensure consistency with the company’s climate change and sustainability strategies. The Committee itself “shall provide oversight of the Corporation’s operations and programs regarding ... public policy and advocacy, including lobbying and political contributions,” demonstrating board-level supervision. While this reflects robust processes for both direct and indirect lobbying alignment, the company does not disclose any publicly available climate-specific lobbying audit or a third-party assessment, and it does not identify a single executive accountable for climate lobbying alignment. View Sources	B

Overall Assessment

Analysis

Score

Strong

BNY Mellon operates a formal governance framework in which its Public Policy and Government Affairs team “reports to the General Counsel and is overseen by the Board of Directors Corporate Governance, Nominating and Social Responsibility (CGNSR) Committee” that “provides regular updates (at least semi-annually) to the CGNSR Committee to set engagement strategy, receive feedback and maintain alignment with business priorities.” This structure extends to its climate-related lobbying, as “formal communications with industry groups and policy makers are generally reviewed, approved and overseen by BNY Mellon’s Corporate Communications and Government Affairs groups” and key input from the “Enterprise ESG and sustainability groups” is sought to ensure consistency with the company’s climate change and sustainability strategies. The Committee itself “shall provide oversight of the Corporation’s operations and programs regarding ... public policy and advocacy, including lobbying and political contributions,” demonstrating board-level supervision. While this reflects robust processes for both direct and indirect lobbying alignment, the company does not disclose any publicly available climate-specific lobbying audit or a third-party assessment, and it does not identify a single executive accountable for climate lobbying alignment.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	BNY Mellon provides only limited transparency around its climate-related lobbying. It indicates that it engages on climate topics through broad initiatives such as the Task Force on Climate-related Financial Disclosures and the Taskforce on Nature-related Financial Disclosures and that it takes part in industry conversations on capital-markets and sustainability regulation, but it does not name any specific bills, regulations, or jurisdictions it has tried to influence. The bank does describe the channels it uses—comment letters, bilateral meetings, and participation in trade associations and investor coalitions—yet it does not identify the particular government departments, regulators, or elected officials it approaches. Finally, its disclosures speak only in general terms about supporting the transition to a low-carbon economy and seeking regulatory clarity, without spelling out concrete policy changes, thresholds, or timelines it wishes to secure. Together, these gaps leave readers with a high-level picture of intent but little detail on the precise policies, lobbying tactics, or outcomes the company is pursuing.	D