BOC Hong Kong Holdings Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	BOC Hong Kong Holdings Ltd provides only limited insight into its climate-policy lobbying. It refers in broad terms to supporting “the HKSAR Government’s green finance initiatives,” to “actively participating in green finance development initiatives undertaken by regulators such as the HKMA and HKEX,” and to being “a cornerstone member of the Alliance for Green Commercial Banks,” but it does not name any specific bill, regulation or rule it has tried to influence. The disclosures identify the regulators it engages with (HKMA and HKEX) yet do not explain how that engagement occurs—no meetings, letters, submissions or other mechanisms are described. Similarly, the company’s objectives remain aspirational; it speaks of “striving to facilitate Hong Kong’s positioning as Asia’s green finance centre,” “expediting the green and low-carbon transition,” and “supporting the HKSAR Government in issuing the world’s first government-issued tokenised green bonds,” without stating what concrete policy changes or legislative outcomes it seeks. As a result, while BOCHK acknowledges general interaction with government-led green-finance programmes, it provides very little detail on the specific policies, methods, or outcomes of any climate-related lobbying.	1

Lobbying Governance

Overall Assessment	Comment	Score
None	BOC Hong Kong Holdings Ltd. demonstrates a well-defined sustainability governance framework—highlighted by its “comprehensive and rigorous three-tier sustainability governance structure” and a Board-level “Sustainability Committee” that “oversees the Group’s sustainability strategies, goals, priorities of material ESG issues and implementation of the relevant initiatives”—but the company does not disclose any governance processes specific to lobbying activities. While the report details how the Board, Risk Committee and Sustainability Executive Committee monitor, manage and report on climate and sustainability risks—such as integrating climate risk into the Group’s risk management system and having the Sustainability Committee “approve the Group’s sustainability objectives and related risks”—we found no evidence of oversight structures, review or approval procedures for either direct lobbying or engagement with trade associations, nor any named individual or formal body responsible for ensuring alignment of lobbying activities with corporate policy.	0