Nordea Bank Abp

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited Nordea Bank Abp provides only limited insight into its climate-policy lobbying. It names one identifiable policy area—the “EU Sustainable Finance Action Plan”/“EU policy on sustainable finance”—but does not cite any additional pieces of legislation or regulations, so its description of the policies it seeks to influence remains narrow. The company is somewhat clearer about how it tries to exert influence: it engages indirectly through its membership of the Norwegian Climate Council, a consultative body that advises the Minister of Climate and Environment, and it also “engages with EU policymakers regarding measures in the EU Sustainable Finance Action Plan.” These two examples reveal both the mechanism (industry body membership and direct engagement) and the relevant targets (the Norwegian Minister of Climate and Environment and EU-level policymakers), yet the disclosures stop short of explaining how those engagements are conducted (e.g., meetings, letters, submissions). On objectives, Nordea states that it seeks “to promote [a] consistent & coherent framework that supports financial sectors’ transition efforts in a predictable way” and that this position is “aligned” with the Paris Agreement, but beyond this single high-level aim it offers no concrete legislative changes or measurable policy outcomes it is pursuing. Taken together, the disclosures show some recognition of the need for transparency but provide only a basic outline of the policies, channels and goals of Nordea’s climate-related lobbying. 1
Lobbying Governance
Overall Assessment Comment Score
Strong Nordea Bank Abp has articulated a governance framework for its climate-related lobbying, with Group Public Affairs (GPA) dedicated to monitoring, analysing and advocating regarding new regulatory initiatives and bound by Nordeas Purpose, Values and Principles as set out in our Code of Conduct and the Code of Conduct of the EU transparency register. Sustainable finance advocacy is managed by a Core Team where each member is selected on the mandate of a GLT member, and the CEO and GLT are responsible for any positions, ensuring top-level oversight of policy stances. This Core Team includes Nordeas representatives in external associations alongside a Group Sustainability (GS) representative who is responsible for ensuring alignment of advocacy activities with Nordeas Group-wide sustainability strategy, including voluntary commitments, demonstrating that both direct and indirect lobbying are actively aligned with the banks climate strategy. Nordea further commits that refraining from participating in lobbying or advocacy activities aimed at weakening climate policy is part of the Nordea Group wide position statement on climate change. We found no evidence of a publicly available audit or a third-party review specifically assessing climate-lobbying alignment. 3