JDC Group AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	JDC Group AG does not disclose any specific governance processes or oversight for its lobbying activities, including those related to climate. The company reports that “JDC Group AG is a member of the Bundesverband Finanzdienstleistung e. V. (AfW),” whose own sustainability initiatives are noted, but there is no description of how JDC aligns or monitors its direct or indirect lobbying efforts with its climate or sustainability commitments. Instead, disclosures focus on legal compliance, stating that “Overall responsibility for compliance with legal requirements lies with the Executive Board, which is responsible for setting up, evaluating and continuously improving the compliance management system,” and that “Group-wide compliance activities are monitored and controlled by a central Corporate Compliance Manager.” The assertion that “Beyond these measures to represent our interests, we are not politically active and generally take a neutral stance on such issues” further indicates the absence of any dedicated lobbying governance framework, with no named individual or committee overseeing lobbying alignment to company goals. View Sources	E

Overall Assessment

Analysis

Score

None

JDC Group AG does not disclose any specific governance processes or oversight for its lobbying activities, including those related to climate. The company reports that “JDC Group AG is a member of the Bundesverband Finanzdienstleistung e. V. (AfW),” whose own sustainability initiatives are noted, but there is no description of how JDC aligns or monitors its direct or indirect lobbying efforts with its climate or sustainability commitments. Instead, disclosures focus on legal compliance, stating that “Overall responsibility for compliance with legal requirements lies with the Executive Board, which is responsible for setting up, evaluating and continuously improving the compliance management system,” and that “Group-wide compliance activities are monitored and controlled by a central Corporate Compliance Manager.” The assertion that “Beyond these measures to represent our interests, we are not politically active and generally take a neutral stance on such issues” further indicates the absence of any dedicated lobbying governance framework, with no named individual or committee overseeing lobbying alignment to company goals.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	JDC Group AG provides only limited insight into its climate-related lobbying. It states that it channels its influence through industry bodies such as the Bundesverband Finanzdienstleistung e. V. (AfW) and the VOTUM association, indicating an indirect lobbying mechanism, but it does not describe concrete actions such as consultations, letters, or meetings, nor does it name the government departments or officials that are approached. The company does not identify any specific climate or sustainability policies, laws, or regulations it has sought to influence, merely noting that the associations take part in “legislative initiatives and regulatory evaluations.” Likewise, the disclosure speaks in broad terms about promoting “sustainability in the finance and insurance industry” without spelling out the precise policy changes or regulatory outcomes it is pursuing. This high-level narrative reveals some involvement in policy discussions but lacks the detail needed to understand what climate measures the company engages on, how it lobbies, or the concrete results it seeks.	D