LHV Group AS – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	LHV Group AS discloses oversight of ESG and investment policies such as “The Supervisory Board of AS LHV Group approves the group’s ESG Policy” and “The Management Board of AS LHV Pank approves the Responsible Investment Policy”, and details that “LHV portfolio managers are responsible for the selection of the additional principal adverse indicators and for ensuring that the impacts are identified”. However, we found no evidence of any internal mechanisms, oversight structures, monitoring, or accountability measures governing its direct or indirect lobbying activities or ensuring alignment of lobbying with climate policy. The company does not disclose any individual, committee, or review process related to lobbying, nor any audits, sign-off procedures, or engagement management with trade associations that could indicate a lobbying governance framework. View Sources	E

Overall Assessment

Analysis

Score

None

LHV Group AS discloses oversight of ESG and investment policies such as “The Supervisory Board of AS LHV Group approves the group’s ESG Policy” and “The Management Board of AS LHV Pank approves the Responsible Investment Policy”, and details that “LHV portfolio managers are responsible for the selection of the additional principal adverse indicators and for ensuring that the impacts are identified”. However, we found no evidence of any internal mechanisms, oversight structures, monitoring, or accountability measures governing its direct or indirect lobbying activities or ensuring alignment of lobbying with climate policy. The company does not disclose any individual, committee, or review process related to lobbying, nor any audits, sign-off procedures, or engagement management with trade associations that could indicate a lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E