Erste Group Bank AG

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong Erste Group Bank AG offers a generally clear picture of its climate-related lobbying, but it concentrates almost entirely on a single initiative – the EU’s Corporate Sustainability Reporting Directive and the associated “EU Sustainability Reporting Standards (ESRS).” The bank explains how it engages, noting it provided “feedback to EFRAG’s consultation on the EFRAG EU Sustainability Reporting Standards (ESRS),” took part in “stakeholder consultations” run by the European Commission, and maintained “constructive dialogue with legislative bodies on EU as well as on national level.” It also identifies the specific targets of these activities, such as “EFRAG,” the “European Parliament (EP), the Council and the European Commission (EC),” demonstrating a high level of transparency on the mechanisms and audiences of its advocacy. The company is equally explicit about what it wants to achieve: it seeks to make certain disclosures voluntary by “changing the disclosure requirements, which are not proportionate to all undertakings, to voluntary disclosures,” calls for a “phase-in process” for mandatory sector-agnostic standards, insists that “the administrative burden for undertakings must remain proportional,” and argues for keeping “the current intra-group exemption” for subsidiaries. While these detailed positions and justifications show a clear line of sight from engagement to desired outcome, the disclosure is focused on one principal policy area, so the breadth of policy coverage remains limited. 3
Lobbying Governance
Overall Assessment Comment Score
Limited Erste Group Bank AG has a public commitment to align its engagement activities with the goals of the Paris Agreement, stating a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and confirming “Yes” when asked about this commitment. However, the company does not disclose any oversight bodies or named individuals responsible for its lobbying governance, nor does it describe any processes for monitoring or managing its direct or indirect lobbying activities, and we found no evidence of specific approval procedures, review mechanisms, or criteria for engaging with industry associations in line with climate objectives, which indicates only limited governance over its climate-related lobbying efforts. 1