Northern Trust Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Northern Trust Asset Management provides a high level of transparency around its climate-related lobbying. It identifies the exact policies it has acted on, including the U.S. Securities and Exchange Commission’s proposed climate-disclosure rule (Release Nos. 33-11042 and 34-94478), the International Sustainability Standards Board Exposure Drafts “IFRS S1” and “IFRS S2”, and the European Financial Reporting Advisory Group’s draft EU Sustainability Reporting Standards. The company describes multiple, clearly identifiable lobbying channels and targets: it “submitted a comment letter” to the SEC, sent a separate comment letter to the ISSB, took part in “public consultations” with EFRAG, and met directly with regulators and corporate boards, as well as working through collaborative platforms such as Climate Action 100+ and IIGCC. It also spells out the outcomes it is pursuing. For the SEC rule it argued that “publicly traded companies should be required to disclose information about their Scopes 1, 2 and, if material, Scope 3 greenhouse gas (GHG) emissions” while recommending adjustments to ease Scope 3 reporting burdens; for the ISSB drafts it backed the creation of “a common international language on sustainability disclosures”; and in Europe it pressed for lobbying-transparency requirements to be embedded in the new reporting standards. Additional requests, such as a global roadmap for sustainable food systems from the FAO, further clarify its policy objectives. By naming the policies, detailing the mechanisms and targets of engagement, and articulating the concrete regulatory changes it seeks, the firm demonstrates comprehensive disclosure of its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
None	Northern Trust Corp provides detailed governance for sustainable investing and stewardship activities but does not disclose any governance processes for lobbying or policy advocacy. For example, "NTAM’s Proxy Voting Committee is responsible for oversight of the Northern Trust Asset Management Engagement Policy" and the firm has "entered into an agreement with Hermes Equity Ownership Services (Hermes EOS) to provide additional monitoring and engagement services for select portfolios," illustrating strong oversight of stewardship engagements. It also notes that "Climate-related stewardship plays a key role in meeting climate objectives across our strategies," and describes how the Sustainable Investing Council "will evaluate reports received from Hermes EOS on a quarterly and annual basis." However, the company does not disclose any mechanisms for governing direct or indirect lobbying activities, no policy or process to align lobbying with its climate commitments, and no individual or board committee is identified as overseeing or reviewing the alignment of lobbying or broader policy advocacy with company goals.	0