PNC Financial Services Group Inc/The

PNC has established structured oversight for its corporate political activities, noting that "all corporate political activities conducted by or on behalf of PNC are managed by our Government Affairs department, which reports to the General Counsel of PNC," and that the Audit Committee "reviews on an annual basis... major lobbying priorities, expenditures made in support of ballot or levy issues and... total dues paid to our principal national trade associations if they exceed $25,000." To align its external engagement with climate objectives, PNC has implemented a deliberate "signatory governance process," designed "to move the organization seamlessly from discussion to decision to declaration to delivery," and uses a DACI decision-making model wherein the Driver engages Contributors, who then present recommendations to an Approver - often a member of the Executive Committee such as the CEO or General Counsel - before briefing those who need to be Informed. This process explicitly evaluates requests "including those around climate change and other environmental issues" for "alignment with PNC corporate values, material ESG issues and Corporate Responsibility goals." However, while this framework addresses sign-on requests and indirect engagement, the company does not disclose a formal mechanism for reviewing its direct lobbying positions in light of its climate commitments, nor does it provide criteria for ensuring the lobbying activities of trade or industry associations are aligned with its Climate Action Strategy, and there is no public audit or dedicated review report on climate lobbying alignment.