Legal & General Group PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Legal & General Group plc, through Legal & General Investment Management, provides an unusually full picture of its climate-policy lobbying. It names a wide range of specific measures it has tried to influence, including the UK rule that would require “the installation of microfibre filters in all new washing machines by 2025,” the US SEC’s proposed climate-related disclosure rule, the FCA’s “Sustainability Disclosure Requirements and investment labels,” reforms to the EU Common Agricultural Policy, the IFRS/ISSB sustainability-reporting standards, the Oil & Gas Methane Partnership disclosure framework, the draft 6th Japanese Energy Plan and associated NDC revision, and the negotiation of a global biodiversity framework and a UN-FAO “roadmap for sustainable agriculture and land use.” It is equally explicit about how and where it lobbies: it “wrote to the European Commission to highlight our recommendations,” “provided a formal response to the consultation” with the FCA, “met with the Environmental Protection Agency to discuss strength of federal methane policies,” joined investor calls with members of Brazil’s Congress on deforestation, sat on the Transition Plan Taskforce steering committee, and participates in technical working groups, round-tables and multilateral negotiations such as COP15. Finally, the company spells out the policy results it is seeking, for instance having “encouraged the Japanese Government to set a 50 % reduction target in their revision of their NDC,” pressing for “mandatory disclosure of Net Zero transition plans for large companies,” strengthening EU and US methane regulations, reforming CAP subsidies to align with the Green Deal, and ensuring high-quality, globally consistent sustainability disclosures. By disclosing the specific policies addressed, the lobbying channels used and the concrete legislative or regulatory changes it advocates, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Legal & General Group PLC has put in place a robust governance framework to ensure its engagement with policymakers and trade associations is aligned with its net-zero ambitions. It specifies that LGIM engages internationally and domestically, both directly with policymakers and indirectly with trade associations to accelerate the transition to net zero and further clarifies that LGIMs dedicated ESG Policy Lead works with colleagues across the business including our parent L&G Group to ensure a coordinated and consistent approach to influencing policy, law or regulation and that this is aligned with our climate strategy and commitment to net zero. Oversight of these activities is entrusted to formal bodies: The Investment Stewardship Committee reports to LGIMs CEO and the LGIM(H) Board, while the Net Zero Working Group and the Responsible Investment Oversight Committee report to LGIMs Executive Committee, up to the CEO and Board, and members of LGIMs Executive Committee, including the CIO, Head of Responsible Investment Integration and Head of Stewardship sit on the L&G Group Environment Committee focused on the Groups strategic response to climate change and reporting into the Group ExCo and Board. While these structures demonstrate clear accountability for both direct and indirect lobbying, we found no evidence of a standalone climate-lobbying alignment report or a third-party audit explicitly evaluating these activities.	3