Lobbying Activities

Like all companies in the financial services industry, State Street is greatly impacted by regulatory decisions on the federal, state and local levels. Where appropriate, we seek to ensure that the firm’s interests are represented as these policies are taking shape. Articulating State Street’s views on legislation or regulation impacting our business to relevant decision makers benefits our stakeholders. Lobbying is an important and legitimate part of the legislative and policy-making process, and such interactions with government officials and legislators may be subject to a variety of regulatory or reporting obligations in various jurisdictions. In all contacts with government officials, State Street employees are required to fully comply with all applicable rules and regulations and the Standards of Conduct.

At State Street, our Regulatory, Industry and Government Affairs (RIGA) division is responsible for monitoring policy, legislative and regulatory developments globally, and for engaging regulators and policymakers on these issues on behalf of State Street, either directly or through trade organizations or outside consultants. As outlined in the Standard of Conduct and the employee Political Contributions and Activities Policy, only State Street’s RIGA division is authorized to retain legislative lobbyists on behalf of State Street. The activities of RIGA’s lobbying professionals and their outside consultant(s) are closely monitored. RIGA’s lobbying professionals must comply with any requirements to attend trainings on applicable laws, adhere to internal compliance policies including the Anti-Bribery and Corruption Policy, and are expected to demonstrate the highest standards of professional integrity. The Nominating and Corporate Governance Committee of the Board of Directors receives periodic reports from the head of RIGA on current legislative trends, upcoming regulatory issues, trade association memberships and lobbying initiatives, expenses and processes. More information on the RIGA division, including recent comment letters filed with regulatory bodies, can be found online at: http://www.statestreet.com/about/regulatory-industry-government-affairs.html.

Lobbying Disclosures:
Consistent with the reporting requirements of the U.S. Lobbying Disclosure Act and the related guidance regularly issued by the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives, we file a quarterly report (Form LD-2) of our U.S. lobbying activities. This report contains a good faith estimate of our total expenditures for U.S. lobbying, including internal expenses, payments to lobbying firms and portions of industry association dues attributable to lobbying activities. The report also includes a general description of our lobbying activity for the relevant quarter, as well as the name of each individual who acted as a lobbyist for each lobbied issue. Our quarterly lobbying reports on Forms LD-2 can be found online at: https://disclosurespreview.house.gov/

We also file semi-annual lobbying reports with the Commonwealth of Massachusetts with respect to our Massachusetts lobbying. As with U.S. filings, these reports include estimates of internal expenses and payments to lobbying firms. The following is a link to find more detailed semi-annual reporting information on our Massachusetts lobbying expenditures: http://www.sec.state.ma.us/lob/lobidx.htm.

Trade Organizations:
State Street participates in and pays membership dues to a number of industry trade organizations. Participation in these organizations is important to gain industry insight, foster relationships and professional opportunities within the business and to collaborate on topics of mutual interest.

Our principal U.S. trade organizations are those to which we pay annual membership fees in excess of $50,000 and, for these purposes, which notify us that a portion of those fees is nondeductible for U.S. income tax purposes. We may not always support or align with the stated position of these organizations or their members, but recognize the importance and overall benefit of our participation in groups that advocate and help to shape public policy. We periodically assess an organization’s scope and purpose to identify where their positions may materially diverge from State Street’s positions, including on environmental, social, and governance (ESG) issues, and evaluate the benefit of continued membership. Our principal U.S. trade organizations are identified below.

Principal U.S. Trade Organizations

American Bankers Association

Bank Policy Institute

Business Roundtable

Financial Services Forum

Greater Boston Chamber of Commerce

Insured Retirement Institute

International Swaps and Derivatives Association (ISDA)

Investment Company Institute (ICI)

Massachusetts Bankers Association

Securities Industry and Financial Markets Association - Asset Management Group

Securities Industry and Financial Markets Association