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| Overall Assessment |
Analysis |
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Moderate
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JPMorgan Chase & Co has put in place a clear governance process for its public policy engagement with the Firm’s “global Government Relations and Public Policy team” pre-approving and managing all Firm-sponsored political activity and expenditures “in accordance with the Firm’s Code of Conduct,” and that GRPP “reports to the Head of Corporate Responsibility who regularly reports to the Public Responsibility Committee (‘PRC’)” of the Board, which “reviews the Firm’s significant policies and practices regarding political contributions, major lobbying priorities and principal trade association memberships” at least annually. The company further commits to “independent decision-making… and providing appropriate feedback on the efforts by these associations, including where there is misalignment between the Firm’s ESG objectives and trade associations positions or activities,” which shows active management of indirect lobbying. However, the company does not disclose a dedicated mechanism for ensuring direct lobbying aligns with its climate objectives or any climate-specific lobbying review or exit process for associations whose positions conflict with those objectives, indicating that its lobbying governance does not clearly address climate-related lobbying alignment.
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C
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| Overall Assessment |
Analysis |
Score |
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Limited
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JPMorgan Chase’s climate-lobbying disclosures are very limited. It references broad policy areas – such as the Inflation Reduction Act, “permitting reform,” methane-emissions standards and the need for “supportive and smart government policy” – but nowhere does the company say it actually lobbied on a named bill or regulation, nor does it supply dates, jurisdictions or any other details that would allow a reader to identify specific laws it tried to influence. The firm likewise offers no concrete description of how it seeks to influence public policy: aside from noting that its Government Relations & Public Policy team reports to the Board and that it “engage[s] regulators” or uses “trade associations,” it gives no examples of meetings, letters, consultations or the government bodies addressed. Finally, although the disclosures stress overarching aims such as helping clients “transition their business,” “mobilizing capital for green technology” and overcoming grid-connection bottlenecks, they stop short of stating the particular legislative or regulatory changes the bank wants to see enacted. As a result, readers receive only a high-level sense that the bank supports climate action, without the specific policies, lobbying channels or concrete outcomes that would demonstrate meaningful transparency.
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D
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