T Rowe Price Group Inc

T. Rowe Price Group Inc. appears to have a defined governance process for its ESG advocacy, including climate-related lobbying, centered on its "Public Policy Engagement and Political Participation Policy" which "governs the firm's approach to advocacy, including through our participation in trade associations." Oversight of these activities is assigned to a newly established global ESG Oversight Committee (ESGOC) chaired by the head of ESG Enablement, and the company explains that "Starting in 2024, ESGOC will review on an annual basis how our direct and indirect ESG advocacy aligns with our commitment to NZAM and the Principles for Responsible Investment (PRI)." The policy also designates the Legislative and Regulatory Affairs team to manage execution and stipulates that "On an ongoing basis, the LRA team will assess this alignment for relevant advocacy projects and follow escalation procedures in case of nonalignment," thus providing both monitoring and escalation mechanisms. The firm further illustrates its direct lobbying efforts by noting its responses to regulatory consultations, stating, "In 2023, we responded to two consultations conducted by the UK government, where we expressed support for the UK's adoption of both of the ISSB standards: IFRS S1 (general sustainability) and S2 (climate-related) disclosure standards." However, we found no evidence of a publicly available dedicated climate-lobbying alignment report or a third-party audit of its lobbying practices, and the timeline for applying the new review process does not reflect retrospective assessments. Moreover, while the policy references indirect advocacy through trade associations, it does not detail specific criteria or thresholds for evaluating or exiting associations whose positions conflict with the firm's net zero commitments.