UBS Group AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	UBS Group AG has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly named multiple specific climate policies it engaged with, including the 'new mandatory reporting requirements for large Swiss companies alongside TCFD,' the 'new law on climate protection which includes a net-zero target for all Swiss companies,' the 'Amendment to the Federal Register of Buildings and Dwellings,' the 'Swiss Climate Scores,' and the 'Revision of the Swiss CO2-Act.' These disclosures provide detailed information about the focus, geography, and measures of the policies, showcasing a high degree of clarity. UBS has also disclosed its lobbying mechanisms and targets, such as direct engagement with members of Parliament, participation in public consultations, financial contributions to trade associations like the Swiss Bankers Association, and collaboration with the Swiss Government and regulatory bodies like FINMA. The company has been transparent about the outcomes it sought, including its support for mandatory reporting requirements, alignment with the Paris Agreement, fostering investment decisions that contribute to climate goals, and advocating for measures like climate compatibility indicators and net-zero alliances. UBS's disclosures reflect a clear and measurable commitment to advancing climate-related policies and objectives, demonstrating a high level of transparency in its lobbying efforts.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	UBS discloses that "UBS' governance of sustainability ensures that relevant functions, up to and including the highest governance level, are informed about and involved in the decision-making on and evolution of UBS' climate change strategy." The Corporate Culture and Responsibility Committee, chaired by the UBS Chairman, "regularly considers UBS' strategy on climate change, including also external engagements & positions and relevant regulatory developments," with further oversight by the Chief Sustainability Office, which ensures that "relevant aspects are communicated to and discussed with the BoD and the GEB and relevant functions within the firm." UBS representatives also participate in external forums such as "GFANZ and the WEF Alliance of CEO Climate Leaders," and the Head Corporate Responsibility chairs a trade association working group that considers climate issues, indicating a defined approach for overseeing climate lobbying efforts at UBS. While the evidence does not describe detailed monitoring mechanisms or a comprehensive review of lobbying alignment, these disclosures indicate strong governance of UBS's climate lobbying activities.	3