Progressive Corp/The

Progressive Corp has established a formal policy clarifying its oversight of political expenditures, stating "Our Policy Statement on Political Contributions, Trade Groups, and Lobbying and our Code of Business Conduct and Ethics guide our actions in the public policy arena" and "require our Personal Lines President and the Law Department to preapprove every political contribution we make." The company also notes that "Our Nominating and Governance Committee reviews the policy statement at least once a year and receives annual reports from management on our compliance with the policy statement." While these measures demonstrate a clear internal sign-off and board committee review for all lobbying and associated political expenditures, Progressive does not disclose any procedures to align its direct or indirect lobbying with climate objectives and has explicitly stated "No, and we do not plan to have one in the next two years" when asked about a commitment to conduct its engagement in line with the Paris Agreement.