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| Overall Assessment |
Comment |
Score |
| Comprehensive |
QBE Insurance Group Ltd has demonstrated a high degree of transparency regarding its climate lobbying activities. The company provides detailed disclosures of its engagement practices by outlining specific lobbying instances – for example, it stated that it "provided feedback to the Australian Accounting Standards Board on the draft requirements in 2022" and that it "took part in the consultation" conducted by the New Zealand Ministry for Environment and Ministry for Business, Innovation and Employment. While some disclosures refer broadly to its participation in partnerships such as the UN‐convened Net-Zero Insurance Alliance and the Insurance Council of Australia's Climate Change Action Committee, QBE also clearly identifies its involvement with specific policy processes – including contributions related to the Australian Government's Bushfire Royal Commission, input on ISSB Exposure Drafts and IFRS standards, and engagement with Cyclone Reinsurance Pool legislation. Furthermore, the company has articulated concrete desired outcomes, outlining measures such as setting a science-based emissions reduction target for 2035 aligned with the Paris Agreement, advancing comprehensive policies to accelerate Australia's transition to net-zero, and advocating for mandatory climate-related financial disclosures. This comprehensive approach to disclosing both its lobbying mechanisms and policy objectives reflects a strong commitment to transparency in its climate lobbying efforts.
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4
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| Overall Assessment |
Comment |
Score |
| Strong |
QBE demonstrates a strong governance process for climate lobbying alignment, as evidenced by its clear governance structure led by the Group Corporate Affairs and Sustainability function. The company ensures that engagement activities are consistent with its overall climate change strategy, stating that "Our climate change strategy and policy-related engagement is led by our Group Corporate Affairs and Sustainability function." QBE describes a detailed process for validating climate change-related public affairs activities, which involves collaboration across different functions and escalation to committees such as the ESG Risk Committee or the Environmental & Social Group Executive Committee Sub-Committee (E&S GEC SC). "As appropriate, this may be presented to our ESG Risk Committee or appropriate sub-committee, and as appropriate escalated to the Environmental & Social Group Executive Committee Sub-Committee (E&S GEC SC) meetings which is Chaired by the Group Executive of Corporate Affairs and Sustainability." The E&S GEC SC includes senior executives such as the Group Chief Risk Officer and Group Chief Underwriting Officer, who ensure alignment with the company's climate strategy and Environmental & Social Risk Framework. "The E&S GEC SC members include the Group Chief Risk Officer, Group Chief Underwriting Officer, Group Chief Financial Officer, Group Chief Technology and Operations Officer who provide steer in relation to our strategic direction to ensure alignment to our overall climate strategy and Environmental & Social Risk Framework." Additionally, QBE participates in industry working groups through memberships in organizations like the NZIA and AOA, aligning its engagement strategy with broader climate objectives. "For the NZIA, we partake in the Anti-Trust Working Group that directly engages with select regulators, as appropriate to influence positively on climate change matters aligned to the scope of the NZIA objectives." This indicates strong governance with monitoring mechanisms, accountability structures, and alignment of indirect lobbying efforts through trade associations.
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3
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