Mediobanca Banca di Credito Finanziario SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Mediobanca discloses that the Chief Executive Officer "has been assigned the oversight of activities relating to sustainability" and that a Board-level "CSR Committee (following CEO proposal)" together with the Board Risks Committee "monitor and supervise activities and processes to ensure they are in line with all CSR related policies". This provides a named individual and formal committees that review whether the Group’s public-facing engagement remains aligned with its sustainability strategy, and the Bank states that these bodies also oversee stakeholder engagement: the CSR Committee "meets at least on a quarterly basis" and "process[es] sustainability proposals/documents to be submitted to the Board’s approval", while the Board describes a process whereby "Both committees monitor and supervise activities and processes to ensure they are in line with all CSR related policies." The company further acknowledges that it actively engages "public authorities, institutions, and industry associations" and intends such engagement to support "the transition path towards achieving the Group's net-zero goals." However, the disclosures concentrate on internal ESG and risk structures rather than on a dedicated mechanism for governing lobbying itself: there is no publicly described procedure for screening direct lobbying positions, no systematic review of trade-association climate positions, and no published lobbying-alignment audit. As a result, while the presence of senior-level oversight and an explicit intention to keep engagement consistent with sustainability policy indicate moderate governance, the company does not disclose detailed processes that would demonstrate active alignment of either direct or indirect lobbying with its climate objectives. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Mediobanca discloses that the Chief Executive Officer "has been assigned the oversight of activities relating to sustainability" and that a Board-level "CSR Committee (following CEO proposal)" together with the Board Risks Committee "monitor and supervise activities and processes to ensure they are in line with all CSR related policies". This provides a named individual and formal committees that review whether the Group’s public-facing engagement remains aligned with its sustainability strategy, and the Bank states that these bodies also oversee stakeholder engagement: the CSR Committee "meets at least on a quarterly basis" and "process[es] sustainability proposals/documents to be submitted to the Board’s approval", while the Board describes a process whereby "Both committees monitor and supervise activities and processes to ensure they are in line with all CSR related policies." The company further acknowledges that it actively engages "public authorities, institutions, and industry associations" and intends such engagement to support "the transition path towards achieving the Group's net-zero goals." However, the disclosures concentrate on internal ESG and risk structures rather than on a dedicated mechanism for governing lobbying itself: there is no publicly described procedure for screening direct lobbying positions, no systematic review of trade-association climate positions, and no published lobbying-alignment audit. As a result, while the presence of senior-level oversight and an explicit intention to keep engagement consistent with sustainability policy indicate moderate governance, the company does not disclose detailed processes that would demonstrate active alignment of either direct or indirect lobbying with its climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	Mediobanca Banca di Credito Finanziario SpA provides almost no transparency on its climate-related lobbying. The disclosures refer only in very general terms to “engaging in constructive, ongoing, and transparent relationships with a range of public authorities, institutions, and industry associations” and note its membership in bodies such as the Italian Banking Association, but they do not name any specific climate policies or regulations the bank has tried to influence. They also fail to describe how it engages—no letters, meetings, consultations, or other mechanisms are identified, nor are any particular government departments or legislators mentioned. Finally, the company offers only broad aspirations like achieving net-zero emissions by 2050 without explaining what concrete policy outcomes it seeks through its lobbying. In short, the disclosures do not give stakeholders enough information to understand whether, how, or why the bank lobbies on climate policy.	E