The State of Asset Manager Stewardship on Climate Lobbying

Executive Summary

• FinanceMap’s assessment of the world’s largest asset managers finds that only a small group of leading firms is conducting robust stewardship of investee companies’ climate lobbying activities. The analysis of 39 of the world’s largest asset managers, collectively representing over $75 trillion in assets under management, shows that many managers are either inactive or inconsistent in their stewardship on the topic. This overall lack of climate lobbying stewardship stands in contrast to recognition by key investor initiatives such as the Net Zero Asset Owner Alliance and Climate Action 100+ of the importance of policy engagement to address the financial risks posed by climate change.

• Between 2021 and 2024, 62% of the assessed managers disclosed that they engaged with investee companies on climate lobbying, while 38% did not disclose any engagements on climate lobbying. The most common theme of engagement was transparency of lobbying activities, followed by trade association activities, and then lobbying alignment with 1.5 °C. Most asset managers that disclosed engagements with companies on climate lobbying did so inconsistently throughout the years assessed.

• Only 10 of the 39 asset managers assessed score a B- or above on stewardship of climate lobbying, while 29 managers score a C+ or below, indicating an absence of robust engagement by the world’s largest asset managers on responsible climate policy advocacy. European asset managers scored higher on average, while North American managers saw scores decrease between 2023 and 2024. Japanese asset managers demonstrated a marked overall improvement in their climate lobbying stewardship between 2021 and 2024.

• Seven asset managers scored within the A-range, demonstrating best practice stewardship on climate policy advocacy: BNP Paribas Asset Management, Federated Hermes, Legal & General Asset Management, Schroders, Boston Trust Walden, Amundi, and Sarasin & Partners. These managers consistently engaged investee companies not only on lobbying transparency, but also on the alignment of their direct policy engagement and their trade associations’ activities with 1.5 °C-aligned policy pathways. They also filed and supported shareholder resolutions, voted against directors and management resolutions, and raised questions at annual general meetings on climate lobbying grounds.

• An assessment of 22 of the asset managers’ 2022–2024 voting records on climate lobbying-related shareholder resolutions unveiled a significant regional split in support for these resolutions. European asset managers were overwhelmingly supportive of climate lobbying shareholder resolutions, with an average of 97% support in 2022, 96% in 2023, and 97% in 2024. North American managers were overall less supportive, with support declining from an average of 58% in 2022 to 39% in 2023 and 36% in 2024. Voting data was not available for the Japanese managers in this report.

Introduction

Background

The Intergovernmental Panel on Climate Change (IPCC) states in its 2022 AR6 Working Group III report that robust climate policy is necessary to mitigate the systemic risk posed by climate change. As a result, investors are increasingly recognizing corporate lobbying on climate policy as a material issue. This is demonstrated by the Investor Statement of Intent from the Global Standard on Responsible Climate Lobbying (“Global Standard”), which states that ambitious climate policy and responsible corporate lobbying are central to limiting global warming and thus financial risk, and that companies’ negative advocacy has often obstructed the net-zero transition, running counter to investors’ interests. In addition, investor groups such as the Net-Zero Asset Owner Alliance (NZAOA) have recognized policy advocacy to be crucial to limiting warming and managing portfolio risk, while the Climate Action 100+ initiative has incorporated climate policy engagement as a key indicator in its Net Zero Company Benchmark.

Apart from their own advocacy on climate policy, which InfluenceMap measures through its Climate Finance Policy Engagement workstream, the world’s largest asset managers have considerable influence over the companies in their portfolios. The NZAOA has called on asset managers to use stewardship as a tool to drive companies to improve their lobbying on climate policy. This is a critical lever of influence to protect the long-term interests of asset managers and their clients and beneficiaries.

About This Report

This report assesses 39 of the world’s largest asset managers on their stewardship of investee companies’ climate policy engagement activities. Collectively, these asset managers represent over $75 trillion in assets under management. The scores featured in this analysis are based on FinanceMap’s assessments of asset managers’ disclosures of stewardship activities and look specifically at how climate lobbying is integrated into the stewardship strategy and actions of the investors. Benchmarks for this analysis are based on external guidance such as the Global Standard on Responsible Climate Lobbying, and assess how an asset manager’s engagements and policies are driving investee companies’ policy engagement to transparently align with 1.5 °C pathways.

FinanceMap’s Research

FinanceMap is a research program by climate think tank InfluenceMap seeking to drive positive change in the financial sector’s impact on climate change, as well as to hold the sector accountable to its climate commitments. FinanceMap produces data and analysis on key actors in the financial sector and assesses to what extent they are using their influence to impact real-economy climate outcomes.

Methodology

Universe

Asset managers were selected by assets under management, with the addition of some smaller managers to ensure regional representation as well as best-practice examples. 35 asset managers were selected. Two of the asset managers (BNY Mellon and Natixis) have been assessed on stewardship via their three main subsidiaries as individual entities, bringing the total number of asset managers included in this report to 39. These, and other asset management subsidiaries that are scored on behalf of their parent company, have the parent company denoted in parentheses in the results table.

Assessment Methodology

The full methodology for this report can be found in the appendix. Scores in this analysis come from publicly available evidence on an investor's stewardship activities, such as stewardship reports and voting guidelines. Evidence pieces are scored against best-practice benchmarks and rated on a scale from -2 to +2, together forming an average top-line score from 1 to 100, which results in an associated letter grade from A+ to F (where 95–100 is A+, 90–95 is A, 85–90 is A-, … and 25 or lower is F). Benchmarks are based on external guidelines such as the Global Standard on Responsible Climate Lobbying. A rating of -2 indicates significant underperformance relative to the benchmark, while +2 conversely indicates evidence of ambitious and positive stewardship of investee companies’ climate lobbying. Evidence factored into the score includes integration of climate lobbying into stewardship and voting policies, case studies of engagements on climate lobbying, and demonstrations of the use of shareholder authority to positively influence companies’ policy advocacy.

This report assesses evidence published from January 2021 up to November 2025. The average top-line score is calculated as the weighted average of all evidence pieces’ scores, where newer evidence is weighted more heavily, to create a measure of an asset manager’s performance on climate lobbying stewardship. In this report, evidence pieces are assigned to their reporting period, even if published in the following year.

Voting on climate lobbying-related shareholder resolutions from 2022 to 2024 is assessed for 22 of the 39 managers in this report, based on data availability. Voting support percentages are based on ShareAction’s Voting Matters data for asset managers with available data in all three years. To calculate a manager’s climate lobbying resolution support percentage, the number of “For” votes is divided by the sum of the total “For” and “Against” votes each year. Voting is not factored into letter grade scores. A full list of the resolutions included in this assessment can be found in the appendix.

Findings

Summary Table

Overview

Only 10 of the 39 asset managers score a B- or above, with 7 of these 10 asset managers scoring an A- or above. The remaining 29 asset managers score a C+ or below, indicating an overall lack of strong stewardship of investee companies’ climate lobbying activities.

Stewardship on climate lobbying has generally improved over time. On average, evidence pieces from 2024 score higher (C-) than those from 2021 (D+). From 2021 to 2023, there was a steady increase in performance of managers’ stewardship on companies’ climate lobbying. However, a drop in scores from North American managers in 2024 has brought down the overall average despite other regions continuing to improve.

As shown in Figure 4, while European and Japanese asset managers have seen a steady increase in performance on stewardship of climate lobbying since 2021, North American managers saw a large drop from 2023 to 2024.

European asset managers, on average across all years assessed, score substantially higher on stewardship of climate lobbying than North American and Japanese asset managers. Correspondingly, five of the seven asset managers that score in the A-range are European, while the remaining two are North American (US headquartered).

Engagement

Out of the 39 asset managers assessed, 24 (62%) disclosed that they engaged on climate lobbying, while the remaining 15 (38%) did not disclose any engagements on climate lobbying between 2021 and 2024. Europe had the highest proportion of asset managers engaged on climate lobbying, with 76% disclosing engagements on the theme, compared to 56% of North American managers and 25% of Japanese managers.

Within these engagements, policy engagement disclosure was the most common theme, with 20 of the 24 engaged asset managers engaging on the topic of transparency of climate lobbying activities between 2021 and 2024. Five of those asset managers engaged only on disclosure and no other climate lobbying concerns. The next most common themes were trade associations and alignment of lobbying activities with the 1.5 °C-goal of the Paris Agreement, with 15 and 14 asset managers engaging on the topics, respectively. Only five asset managers disclosed engagements on companies’ positions on specific climate policies.

Many of the asset managers who engaged with companies on climate lobbying over the years disclosed on it inconsistently, making it difficult to assess the extent to which they are consistently engaging on the topic. Some asset managers have disclosed only one or two engagements on the topic in the four-year span assessed. For example, in 2023, RBC GAM encouraged an unnamed Canadian energy company to publish climate-related lobbying disclosures; however, in the other years assessed it did not disclose any engagements on climate policy advocacy. Similarly, in 2022, Newton IM asked German healthcare and agriculture company Bayer about the climate change position of one of its trade associations, CropLife America, but has not disclosed any other engagements on the topic.

Best Practice

Best practice stewardship on climate policy engagement is demonstrated by asset managers engaging consistently and widely across companies and sectors in their portfolios. Seven of the 39 asset managers assessed score within the A-range on stewardship of climate lobbying: BNP Paribas Asset Management, Federated Hermes, Legal & General Asset Management, Schroders, Boston Trust Walden, Amundi, and Sarasin & Partners.

Best practice means actively engaging with companies beyond the topic of lobbying disclosure. Ambitious stewardship on climate lobbying, when done consistently, can involve:

• Encouraging companies to align direct lobbying activities with 1.5 °C;

• Driving companies to address misalignment between their own climate goals and policy positions and those of their industry associations;

• Engaging companies to advocate on specific policies in alignment with the net-zero transition;

• Filing shareholder resolutions on climate lobbying or voting against directors on climate lobbying grounds.

Some examples of asset managers exhibiting best practice stewardship include:

• Over the past few years, Federated Hermes has engaged with several automakers on climate lobbying topics. It has engaged with BMW, Volkswagen, and Mercedes to close the gap between their current lobbying disclosures and the Global Standard on Responsible Climate Lobbying; with Stellantis and Renault on their public policy advocacy reporting; and with Toyota, Honda, and Suzuki to encourage further alignment with the Global Standard. Additionally, in 2024 it raised questions at several Canadian banks’ annual general meetings (AGMs) (RBC, TD Bank, Scotiabank, and BMO), asking if they had conducted a review of their trade associations and lobbying activities to ensure alignment with their own climate commitments and Canada’s net-zero goal.

• In 2024, Legal & General Asset Management co-filed a shareholder resolution at Nippon Steel following extensive engagement on the company’s insufficient climate-related lobbying disclosures. Other engagements in 2024 drove Fortum to improve its 2025 climate lobbying disclosures and Nucor to publish a lobbying report in 2025. Legal & General has laid out clear expectations for investee companies on climate lobbying and set a “red-line” for 20 climate critical sectors on their climate lobbying activities. This means it may vote against the chair or equivalent at a company’s AGM if it is not meeting expectations on climate lobbying.

• Sarasin & Partners has engaged with Rio Tinto for many years to push for a net-zero aligned lobbying commitment, accompanied by lobbying disclosures and exits from misaligned trade associations. As a result, Rio Tinto published an updated review of its climate advocacy in 2023, although the company has resisted exiting misaligned trade associations. Sarasin has stated that it will continue to pressure the board on this issue. Additionally, Sarasin has engaged with Air Liquide on climate lobbying concerns, resulting in the company exiting the American Fuel & Petrochemical Manufacturers due to misalignment with climate positions in 2024.

• BNP Paribas Asset Management states that it will abstain or vote against Say on Climate, discharge of board and management, board re-elections, and financial statements at companies that are priority companies on climate lobbying and do not align with its expectations on climate lobbying reporting. In addition, it has engaged with many companies across sectors and regions on their climate lobbying activities and alignment with the Global Standard over recent years, including Iberdrola/Avangrid, BASF, Carrefour, Saint-Gobain, Danone, OMV, Stellantis, Nestlé, and Unilever in 2024 alone.

Shareholder Resolutions and Voting

Investors can exercise their shareholder authority to influence investee companies on their climate policy advocacy by filing and/or voting on shareholder resolutions. Only five of the 39 asset managers assessed disclosed that they had filed shareholder resolutions on climate lobbying between 2021 and 2024: BNP Paribas Asset Management, Legal & General Asset Management, Schroders, Federated Hermes, and Boston Trust Walden.

Voting

Based on data availability,¹ 22 of the 39 asset managers have been assessed on their voting on climate lobbying shareholder proposals from 2022 to 2024. The managers’ percent support of the selected shareholder proposals over the three years is shown in Table 3.

European asset managers were highly supportive of climate lobbying shareholder resolutions in all three years assessed. As shown in Figure 6, European managers on average supported 97% of the selected resolutions in 2022, 96% in 2023, and 97% in 2024. North American managers were not as supportive overall, and support decreased substantially in recent years from an average of 58% support in 2022 to 39% in 2023 and 36% in 2024. There was also greater variation between North American managers in their support of climate lobbying resolutions. Some managers demonstrated consistently high levels of support, such as Manulife IM and Federated Hermes. Others’ support declined from 2022 to 2024, including J.P. Morgan Asset Management and Invesco, while some showed consistently low support, such as BlackRock, Vanguard, and State Street.

Conclusion

As this report has demonstrated, the worlds’ largest investors are increasingly putting climate policy engagement on the stewardship agenda. However, only a small handful of asset managers are engaging actively and robustly on this topic. A critical mass of managers does not appear to be driving investee companies to advocate for climate policy in alignment with science-based pathways.

Over one-third of the asset managers assessed did not disclose any engagements on climate lobbying, and of those that did, many appeared to engage inconsistently in recent years. A select few asset managers, particularly in Europe, demonstrated leadership in stewardship on the topic, engaging continually with investee companies, setting clear expectations, and filing and supporting climate lobbying shareholder resolutions. Similarly, European asset managers consistently voted in support of climate lobbying resolutions, further signaling the importance of the issue to investors, while others’ support, particularly in North America, was low or inconsistent.

As recognized by key investor initiatives such as the Net Zero Asset Owner Alliance and Climate Action 100+, investors should utilize their influence over portfolio companies to safeguard long-term returns by driving these companies towards positive climate policy advocacy and away from obstructive engagement and misaligned trade associations. Asset managers should recognize the materiality of climate lobbying and encourage alignment of companies’ policy advocacy with 1.5 °C through engagement, voting, and shareholder authority. In conclusion, policy engagement should be a key issue on asset managers’ stewardship agendas if they are to serve the interests of their clients and beneficiaries and protect portfolios from the systemic risks posed by climate change.

Appendix: Methodology

Throughout this document, the term “stewardship” is used to refer to all private and public communications and investor mechanisms by which investors influence the companies in their portfolios. This includes:

• Communications and meetings between corporate management and appointed advisors;

• Questions at annual general meetings or other company meetings;

• Comments on the company in the media or public forums; and

• Shareholder resolution measures and voting.

FinanceMap assesses stewardship by analyzing publicly available evidence on an investor's stewardship activities against industry-standard and science-based benchmarks defining ambitious and robust climate stewardship. FinanceMap's wider stewardship assessment was originally developed in 2020, using the UK Financial Reporting Council's (FRC) 2020 Stewardship Code as its key benchmark. FinanceMap has since implemented additional benchmarks to update the methodology’s scoring criteria. These include documents and guidelines released by recognized industry initiatives, including the Net Zero Asset Owner Alliance, Institutional Investors Group on Climate Change, Paris Aligned Investment Initiative, and the Global Standard for Responsible Climate Lobbying.

Stewardship Assessment Methodology

For its overall stewardship assessment, FinanceMap uses a series of twelve queries, constructing a matrix of queries (Q1...Q12) against data sources (D1/D2) for each investor. This report focuses on one query, Q5, Engagement on Climate Lobbying. All publicly available evidence on the investor’s relevant activities and processes is scored against qualitative scoring guidelines on a five-point scale from -2 to +2. A score of -2 indicates the evidence demonstrates significant underperformance relative to the benchmarks, while +2 conversely indicates evidence of ambitious and positive stewardship activity. The data sources analyzed primarily include asset managers’ own reporting and disclosure (e.g., stewardship reports, ESG reports). The scores for all evidence pieces within the query are weighted together to create a top-line score from A+ to F, and more recent evidence pieces weigh higher on the score than older ones.

Q5: Engagement on Climate Lobbying

As InfluenceMap has demonstrated through consistent analysis since 2015, corporations remain a primary obstacle to the progress of climate change legislation. Investors play a key role in bringing about corporate behavior change to ensure companies’ direct and indirect policy footprints are consistent with the ambition of the Paris Agreement. Released in March 2022 and updated in July 2025, the Global Standard on Responsible Climate Lobbying was created to provide a “framework to ensure companies’ lobbying and political engagement activities are in line with the goal of limiting global temperature rise to 1.5 °C above pre-industrial levels.” Asset managers score highly on Q5 if they are actively and ambitiously engaging with investee companies to align their policy influence with 1.5 °C, in line with the “action” standards of the Global Standard. This includes driving companies to publish detailed reviews of their direct and indirect lobbying activities’ alignment with 1.5 °C and to address any misalignments of their own lobbying or that of their trade associations. Additionally, asset managers taking strong action such as escalating engagements, voting against directors, or filing shareholder resolutions on climate lobbying grounds receive high scores. If climate policy advocacy is integrated into an asset manager’s stewardship policies, it is also scored; however, an asset manager must also have examples of engagements with companies to score highly.

This report assesses evidence published from January 2021 up to November 2025. The average top-line score is calculated as the weighted average of all Q5 evidence pieces’ scores, where newer evidence is weighted more heavily, to create a measure of an asset manager’s performance on climate lobbying stewardship. In this report, evidence pieces are assigned to their reporting period, even if published in the following year. For example, an evidence piece published in May 2025 that covers an asset manager’s stewardship activities from January 1, 2024 to December 31, 2024 would be attributed to 2024 in any year-by-year analysis.

Voting

Voting on climate lobbying-related shareholder resolutions is assessed separately and is not factored into the top-line score of asset managers on this query. This assessment uses data from ShareAction’s Voting Matters from 2022 to 2024. Two managers (PIMCO and Insight Investment) are primarily fixed income investors and thus voting assessment is not applicable. This report assesses the 22 asset managers for which ShareAction data was available for all three years. Resolutions included in the assessment are listed below, and were selected if they asked for positive change in companies’ climate lobbying activities—either through improved transparency or alignment with 1.5 °C. To calculate a given manager’s climate lobbying resolution support percentage, the number of “For” votes is divided by the sum of the total “For” and “Against” votes each year. Abstentions and “did not vote” outcomes were omitted. ShareAction categorizes split votes as “Split – For” where over 75% of the assets held in a company voted in favor of the resolution, “Split – Against” where over 75% of the assets held in a company voted against or abstained, and “Split” where data was insufficient to determine. For this assessment, “Split – For” was categorized as “For” and both “Split” and “Split – Against” were categorized as “Against.”