US Bancorp

US Bancorp has established a clear governance process to align its lobbying and policy engagement activities with its climate change strategy by ensuring that "direct and indirect activities are reviewed and approved by a level of senior management not more than three levels removed from the CEO." This begins with the Environmental Program Manager, who "reviews them within the context of our Environmental and Social Risk Policy, as well as U.S. Bancorp's established environmental strategy," and culminates in a decision made "in collaboration with the Executive Vice President, Chief Social Responsibility Officer and is reflective of U.S. Bancorp's climate change strategy and policy." Oversight is reinforced by the ESG Committee and Climate Risk Working Group, "comprised of senior leaders representing business and enablement functions across the company," and by the Public Responsibility Committee, which "reviews public policy matters that impact our company's business activity," supervises ESG strategy updates and "holds management accountable for progress." While this indicates strong governance across both direct and indirect lobbying channels, the company does not disclose a public commitment to align its engagement with the goals of the Paris Agreement, nor does it publish a dedicated audit or third-party report evaluating the alignment of its climate-related lobbying activities.