Banco Santander Brasil SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Banco Santander Brasil SA demonstrates a comprehensive level of transparency in its climate lobbying activities. The company explicitly identifies specific climate policies it has engaged with, such as "Mercado de Carbono (PL 412/2022, PL 3100/22, PL 2229/2023, PL 528/2021)," "Taxonomia Ambiental (PL 2838/2022)," "Desmatamento e rastreabilidade (PL 1858/2022)," and the "RenovaBio Program" along with the regulation of CBIOs. It also mentions its contributions to discussions on "regulatory and legislative prerequisites for the implementation of the Brazilian Nationally Determined Contributions (NDCs)," demonstrating clear transparency in naming the policies and legislative frameworks involved. Santander provides detailed descriptions of its lobbying mechanisms, including direct engagement through participation in the "Forum Brasileiro de Mudanças Climáticas (Brazilian Forum for Climate Change)," which is chaired by the president of Brazil, and indirect engagement through the Brazilian Bank Federation (Febraban) to influence green bonds regulation. Additionally, the company participated in consultation groups and contributed to reports with suggestions to the Ministry of Mines and Energy (MME), showcasing both the mechanisms and specific targets of its lobbying efforts. Santander also outlines specific outcomes sought, such as fostering the issuance of Green Bonds or Climate Bonds in the Brazilian market, contributing to the implementation of the National Policy for Climate Change, and influencing market regulation for CBIO issuance and registration. These disclosures reflect a clear and detailed intent to influence specific policy outcomes related to climate change mitigation and legislative frameworks, demonstrating a high level of transparency in its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Santander has established a comprehensive governance framework for climate lobbying alignment, encompassing both direct and indirect lobbying activities. The company has disclosed detailed processes, responsible parties, and monitoring mechanisms to ensure alignment with climate goals. For instance, the Responsible Banking Forum (RBF) acts as the executive governance body that "reviews implementation of the Group's responsible banking agenda and presents its findings to the RBSCC." The RBF drives decision-making on responsible banking issues and enforces mandates from various committees, including the Board Responsible Banking, Sustainability and Culture Committee (RBSCC), which "supports the Board of Directors in supervising the Group's responsible banking agenda and strategy." The RBSCC has five independent board members and has discussed climate change in multiple meetings, reviewing topics such as "progress on power generation and thermal coal portfolio alignment targets" and "latest targets for disclosure of energy (oil and gas), steel, and aviation." Santander has also implemented a tiering system to assess the alignment of its customers' emissions profiles and transition plans with its climate goals. This system categorizes customers into four tiers based on their emissions trajectory and the quality of their transition plans, which are assessed across four pillars: "Targets, Action Plan, Disclosure, and Governance." The company has expanded this tiering assessment to include sectors such as energy, steel, and aviation, and has enhanced its methodologies with updated benchmarks and sector-specific research. Furthermore, Santander has created specialized roles to oversee its green finance and ESG initiatives, such as the Global Head of ESG & Sustainable Tech and the Global Head of Green Finance, both of whom report directly to the CEO. The company also conducts annual risk assessments and internal audits to monitor progress on climate-related initiatives, ensuring alignment with its policies and targets. For example, its Internal Audit area audited climate risk management in 2022 to "check that the Group's initiatives were progressing according to plan" and suggested ways to strengthen governance and controls. Santander has published detailed reports, such as the Climate Finance Report, which provide transparency into its lobbying activities and alignment with climate goals. The report includes updates on decarbonization targets, sector-specific action plans, and the Sustainable Finance Classification System (SFCS), which tracks lending activities that mitigate or adapt to climate change. Additionally, the company collaborates with external organizations, such as the University of Oxford, to develop best practices and tools for transition finance. Overall, Santander's governance framework demonstrates a robust approach to managing climate lobbying alignment, with clear accountability structures, detailed monitoring processes, and proactive engagement with stakeholders to ensure alignment with its climate goals.	4