Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The Bank of New York Mellon (BNY) and subsidiaries BNY Investment Management, Insight Investment, and Newton Investment Management appear to be engaged on climate-related policies in the US, EU, and UK, with mixed positions. The bulk of policy engagement appears to come from Insight, in Europe.
Top-Line Messaging on Climate-Related Financial Policy: In its 2022 response to the UK Green Finance Strategy Update, Insight Investment recognized the issue of short-termism in the financial system but stated that it is an “open question” as to whether financial markets can be restructured to address this. Subsidiaries Insight and Newton signed onto the Investor Agenda’s 2022 Global Investor Statement, advocating for governments to take action to limit temperature rise to 1.5C. Also in a 2022 Responsible Investor article, BNY IM appeared supportive of urgent action to tackle climate change. In its 2022 ESG Report BNY reported engaging on climate-related issues with policymakers, but details of this engagement are unclear. In 2022 comments to HM Treasury, BNY supported an update of regulatory principles for sustainable growth to reference climate change and a net-zero economy.
Position on Regulated Corporate Climate Disclosure: BNY has taken a mixed position on climate disclosure, broadly supporting the need for disclosure but outlining objections to specifics of some policies. Insight and Newton signed on to the 2022 Global Investor Statement, calling on policymakers to mandate TCFD-aligned reporting and require disclosure of 1.5C pathway-aligned transition plans. In a 2022 release, the head of Responsible Investment for Insight welcomed the SEC’s efforts to require corporate climate disclosures. In 2022 comments on the UK Green Finance Strategy Update, Insight supported efforts to enhance climate disclosure but asserted that Scope 3 emissions disclosure should only be mandated after consistent methodologies and standards have been developed, encouraging the UK to lead this effort. In Insight’s 2024 Responsible Stewardship Report it supported the UK Transition Plan Taskforce’s transition plan disclosure framework and implementation guidance but highlighted challenges for companies operating across jurisdictions and advocated for interoperability.
Position on Climate Standards/Labels/Benchmarks: In Insight’s 2024 Responsible Stewardship Report it detailed engaging with the Australian government on its green bond framework, supporting requirements around clearly defined use-of-proceeds. In a 2022 letter Insight took a mixed position on ESMA’s efforts to introduce quantitative thresholds for funds using ESG terms in their names, supporting the 80% threshold but not supporting Paris Alignment Benchmark exclusions. According to its 2024 report, Insight wanted further changes to ESMA’s final rules, but what these changes are is unclear. BNY IM advocated for several changes to the UK FCA’s proposed investment labels in 2023 comments, raising concerns about timeline, data availability and criteria for stewardship under the “Sustainable Improvers” label, and restriction on the use of certain terms. Insight appeared supportive of the final SDR labels in its 2024 report.
Position on Incorporating Climate Factors Into Investor Duties: In its 2022 Responsible Stewardship report, Insight supported a US Department of Labor rule that would permit fiduciaries to consider climate risks in investment decision making. However, in 2022 comments to the Department, Insight did not support a requirement for retirement plans to report on climate risks. Similarly, in 2022 comments to the UK Department for Work and Pensions Insight suggested that it was premature to require trustees to report on the Paris alignment of pension schemes. In 2023 comments BNY Mellon IM objected to proposed stewardship requirements in the FCA’s Sustainability Disclosure Requirements but supported proposed consumer-facing disclosures. Also in the UK, Insight has called for more clarity around trustees’ legal obligations to facilitate increased investment in green bonds and increased use of ESG factors in investing. In the EU, Insight has objected to a number of technical elements to the Sustainable Finance Disclosure Regulation (SFDR) in 2023 comments and its 2024 report.
Position on Real Economy Climate Policies: In its 2024 Responsible Stewardship report Insight details engaging with the Australian government on its 2035 emissions reduction plan, though details of this engagement are unclear.
Position on Energy, Industry, and Land Transitions: BNY appears generally supportive of the energy transition. A 2022 report outlined a position on hydrogen that is aligned with IPCC guidance, suggesting hydrogen can be useful for transferring off of gas. The same report called for government action to decarbonize the economy. Insight’s 2024 Responsible Stewardship report detailed engagement with the UK government where Insight outlined concerns that the UK policy environment is not ambitious enough to meet net zero targets and opposed the government’s approval of a new coal mine in Cumbria. Additionally, in a 2023 ESG Investor article BNY appeared supportive of the climate investments in the US Inflation Reduction Act.
Industry Association Governance: BNY and its subsidiaries have disclosed membership to industry associations, but without providing details of these groups' climate-related positions or engagement activities.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q1 2025.