Capital One Financial Corporation

In terms of senior leadership accountability, the responsibility for sustainability issues within Capital One lies with the board of directors and its Governance and Nominating Committee. The financial institution discloses that it has performed a pay gap analysis to address any gender pay gaps. Furthermore, the financial institution discloses a list of trade associations of which it is a member including sustainability- and non-sustainability-related organisations.

Capital One discloses that it has invested over USD 750 million into renewable energy since 2014 and around USD 8 billion into sustainable housing projects since 2016. Moreover, it has financed over USD 10 billion in renewable energy and sustainable building investments since 2015.

Capital One has a grievance mechanism accessible to all workers, external individuals and communities to raise human rights complaints or concerns. The financial institution has a publicly available policy statement which shows it is committed to respecting the health and safety of workers. The financial institution has a policy prohibiting bribery and corruption as well as a grievance mechanism for stakeholders to raise concerns and complaints regarding bribery and corruption.

In terms of its approach to senior leadership accountability, Capital One could provide more details regarding how it links the remuneration of its executive or management teams to sustainability performance criteria. No evidence was found that the financial institution commits to gender equality and women’s empowerment. In terms of female representation in leadership positions, women are underrepresented on the board of directors where only three out of 12 board members are women. The financial institution has an opportunity to describe its group-level engagement approach on sustainability themes and impact topics with clients.

There is no evidence that Capital One discloses a target to reach net-zero financed emissions by 2050. The financial institution has an opportunity to disclose the key sectors and companies it has identified as priorities to engage with on climate change, specifically on the alignment with the Paris Agreement. The financial institution could align its climate solutions for renewable energy and sustainable housing projects with internationally recognised frameworks. Regarding nature and biodiversity, the financial institution could make a commitment to minimising its negative impacts or financing regenerative solutions beyond its minimal exposure to forest-related lending and sustainable paper procurement.

There is no evidence that Capital One has a publicly available policy statement committing it to respect human rights. The financial institution has an opportunity to describe a comprehensive process for identifying its human rights risks and impacts across all its activities, especially its financing activities. To provide transparency on financial inclusivity, the financial institution has an opportunity to disclose the amount of finance directed towards, for example, women-owned businesses, small- and medium-sized enterprises (SMEs) or low-income developing countries.