Banca Mediolanum SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Banca Mediolanum has established an oversight mechanism in which “The Committee also oversees and reviews, at least annually, the company's public policy agenda, its position on significant public policy matters, political contributions and lobbying activities,” and it names that “The North America Operating Unit Vice President of Public Policy, Federal Government Relations & Political Engagement is responsible for management of our public policy agenda and political engagement.” This indicates clarity on who manages and periodically reviews lobbying activities. However, we found no evidence of any process to align these activities with its climate objectives or a commitment to the objectives of the Paris Agreement, and the company explicitly states “No, and we do not plan to have one in the next two years,” demonstrating the absence of climate-specific lobbying governance or alignment mechanisms. View Sources	D

Overall Assessment

Analysis

Score

Limited

Banca Mediolanum has established an oversight mechanism in which “The Committee also oversees and reviews, at least annually, the company's public policy agenda, its position on significant public policy matters, political contributions and lobbying activities,” and it names that “The North America Operating Unit Vice President of Public Policy, Federal Government Relations & Political Engagement is responsible for management of our public policy agenda and political engagement.” This indicates clarity on who manages and periodically reviews lobbying activities. However, we found no evidence of any process to align these activities with its climate objectives or a commitment to the objectives of the Paris Agreement, and the company explicitly states “No, and we do not plan to have one in the next two years,” demonstrating the absence of climate-specific lobbying governance or alignment mechanisms.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E