KeyCorp

In terms of senior leadership accountability, the responsibility for sustainability issues within KeyCorp lies with the Nominating and Corporate Governance Committee of the board. In addition, KeyCorp discloses actions it takes to address any gender pay gaps, such as maintaining a formal compensation structure to establish pay on the basis of objective factors, regularly reviewing this structure considering market trends and internal equity and implementing a pay-for-performance philosophy. Furthermore, KeyCorp discloses a list of trade associations of which it is a member including sustainability- and non-sustainability-related organisations.

KeyCorp discloses the aggregate amount and share of finance it devotes to climate solutions while specifying what these solutions are.

KeyCorp discloses the proportion of women in its total direct operations workforce for each employee category and the proportion of its total direct operations workforce for each employee category by race or ethnicity. Furthermore, KeyCorp has a grievance mechanism accessible to all workers and external stakeholders to raise human rights complaints or concerns or bribery and corruption complaints. In addition, KeyCorp discloses the proportion of its total direct operations workforce covered by collective bargaining agreements.

In terms of its approach to senior leadership accountability, KeyCorp could link the remuneration of its executive and management teams to sustainability performance criteria. KeyCorp has an opportunity to describe its engagement approach on sustainability themes and impact topics with clients and investees. KeyCorp also has an opportunity to provide a public commitment 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 four out of 13 board members are women, and the bank could reach at least 40% female representation in senior leadership positions. KeyCorp could also disclose the ratio of basic salary and remuneration of women to men in its total direct operations workforce for each employee category.

KeyCorp has an opportunity to disclose a target to reach net-zero financed emissions by 2050 and the key sectors and companies it has identified as priorities to engage with on climate change, specifically on the alignment with the Paris Agreement. KeyCorp could align its climate solutions (bond offerings) with internationally recognised frameworks and disclose time-bound targets explicitly for them. Regarding nature and biodiversity, KeyCorp has an opportunity to show how it is committed to minimising its negative impacts or financing regenerative solutions. No evidence was found regarding KeyCorp’s approach to fossil fuels that spans across the fossil fuel value chain, such as the amount or share of finance it directs towards fuels, or its stance on financing companies with new fossil fuel projects.

KeyCorp could provide a publicly available policy statement committing it to respect human rights laid out in the UN Guiding Principles and the ILO declaration on fundamental rights at work. KeyCorp could also provide a publicly available policy statement committing it to respect the health and safety of workers. KeyCorp also has an opportunity to describe a comprehensive process for identifying its human rights risks and impacts across all its activities, especially its financing activities. Moreover, while KeyCorp discloses the ages of its board members and executive officers, it could disclose this information for each employee category. To provide transparency on financial inclusivity, KeyCorp 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.