KeyCorp

KeyCorp demonstrates a clearly defined climate lobbying governance process that includes formal oversight bodies and structured review steps, but it does not provide evidence of a standalone climate lobbying report or an external audit of its lobbying alignment. In particular, "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," illustrating specific governance bodies responsible for policy influence. Furthermore, "positions are reviewed by Government Relations and our Corporate Responsibility Group to confirm they remain consistent with Key's overall climate change strategy," establishing a concrete mechanism to monitor and manage lobbying alignment. The company also clarifies that "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," which indicates governance across both direct and indirect lobbying channels. While these elements demonstrate robust oversight and alignment procedures, we found no evidence of a dedicated climate lobbying report, third-party audit, or a named individual solely overseeing climate lobbying alignment.