Our company is active in numerous public policy debates and lobbying on key issues affecting it financially, including issues like tax reform, trade policy, climate change. JPMorgan Chase describes values and beliefs guiding the Company in its Sustainability Report. But sometimes trade associations or other organizations to which they belong or contribute, advocate for policies that contradict or undercut company positions. Companies with serious misalignment face reputational risk and, where misalignment involves issues core to value creation, risk to the business. For example, climate change poses systemic financial risk, potentially reducing global GDP by up to 19% by midcentury. 1 Corporate lobbying and policy action inconsistent with mitigating negative climate impacts and transitioning to a low carbon economy may present risks to investors and companies. It is important for JPMorgan Chase to assess how their trade associations or politically active nonprofits they support lobby on climate laws and regulations. For example, the bank presently supports ALEC, a controversial organization that promotes model legislation for states which attack work on diversity or climate change. In addition, the bank was identified as the State Financial Officers Federation (SFOF), which has waged a coordinated attack on climate policy.2 The company risks reputational damage by funding organizations lobbying against climate legislation, contradicting its public statements and potentially undermining achievement of its climate goals. Another example is lobbying by trade associations to limit shareholder rights and their ability to file resolutions3 while in contrast the company respects and values its engagements with investors. We commend the company for its present disclosure of lobbying and oversight. However, current disclosures do not adequately explain how the Company ensures its lobbying aligns with its public policy positions and how it manages policy misalignment risks. Such a review does not automatically lead to ending membership in such organizations but could include expanding ways to engage and change that organization. While we would expect that management oversees involvement in trade associations and politically active nonprofit organizations, we believe JPMorgan Chase should deepen scrutiny of their actions, how they analyze alignment with their advocacy and describe options when contradictions arise. We urge JPMorgan Chase to issue a lobbying alignment report similar to those published by Ford, General Motors, Honeywell, United Airlines and Unilever. 1 https://www.nature.com/articles/s41586-024-07219-0 2 https://www.nytimes.com/2 022 /08/05/cl ima te/republ ican-treasu rers-c Ii mate-change. htm I 3 https://www.businessroundtable.org/business-roundtable-calls-for-bold-reform-of-thecorporate- proxy-process-io-oew-white-paper