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Analysis |
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None
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Wuestenrot & Wuerttembergische AG discloses that "The W&W Group does not engage in any lobbying activities of its own," noting that its "political commitment is exercised in particular through its association memberships in the associations Verband der privaten Bausparkassen e.V. (VdPB), Verband deutscher Pfandbriefbanken e.V. (vdp) and Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV)." The company does not describe any governance process, oversight structure, or accountability measures for either direct or indirect lobbying. We found no evidence of a policy to ensure alignment of political engagement with company goals, no named individual or board committee overseeing lobbying, and no mechanism for monitoring or reviewing the positions of its trade association memberships.
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E
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| Overall Assessment |
Analysis |
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Comprehensive
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Wüstenrot & Württembergische AG is fully transparent in explaining that it undertakes no direct climate-policy lobbying. The company states, "The W&W Group does not engage in any lobbying activities of its own," and clarifies that any political engagement occurs only through membership in industry bodies such as "Verband der privaten Bausparkassen e.V. (VdPB), Verband deutscher Pfandbriefbanken e.V. (vdp), and Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV)." Because it undertakes no direct lobbying, the company appropriately does not list individual climate policies, instead explicitly confirming that there are none. It also explains its mechanisms—limited to participation in association working groups and public consultations run by bodies like BaFin—while naming the specific associations that act on its behalf. Finally, by confirming it seeks no specific policy changes itself and describing how its association memberships substitute for direct advocacy, the company makes clear that no lobbying outcomes are being pursued. This frank disclosure of non-engagement, the rationale for this approach, and the identification of the forums through which any indirect influence might occur demonstrate a comprehensive level of transparency on climate-related lobbying activities.
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A
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