DBS Group Holdings Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	DBS Group Holdings provides a solid level of transparency on its climate-related public-policy engagement. It identifies two concrete policy areas it seeks to influence – Singapore’s move to introduce “mandatory climate reporting” (which the bank says it “support[s] with no exceptions”) and the Singapore Exchange Regulation initiative to develop a “Guide for climate-related disclosures and [a] framework for green trade finance.” The company is also clear about how it pursues these objectives: it sits on the Sustainability Reporting Advisory Committee established by ACRA and SGX RegCo, serves on the Green Skills Committee convened by the Ministry of Trade and Industry and SkillsFuture Singapore, and undertakes “direct engagement with the Singapore Stock Exchange (SGX)” where it co-leads workstreams, drafts consultation papers and prepares guidelines and whitepapers. Through these channels DBS aims to ensure that climate disclosure rules are adopted and that reporting is aligned with TCFD, and to strengthen guidance for green and transition finance so that disclosures across sectors are “more consistent and comparable.” While the bank’s disclosures concentrate on reporting and finance rules rather than a broad suite of climate laws, they still spell out specific policies, mechanisms and desired outcomes, demonstrating a strong degree of clarity over its lobbying activities.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	DBS Group Holdings Ltd describes a robust sustainability oversight structure, with a Board Sustainability Committee that “oversees DBS’ overall plans and approves its strategies, goals, and targets in relation to material environmental and social issues,” supported by a Group Sustainability Council and Climate Steering Committee focusing on climate risk management. The bank also notes that “we engage regularly with regulators, government, and public agencies in in-depth discussions on climate-related matters (e.g., green finance taxonomy, climate-related disclosures) and actively participate in local, regional, and international industry forums on financial regulations, including sustainability disclosures,” and confirms “Yes” to having a public commitment to align its engagement activities with the goals of the Paris Agreement. However, the company does not disclose any formal policy, sign-off procedures, audit, or dedicated oversight body to govern the alignment of its lobbying or public policy engagement with its climate strategy, and we found no evidence of any process to review or monitor either direct or indirect lobbying activities. This indicates that, despite strong sustainability governance structures, specific governance for lobbying remains limited and opaque.	1