QBE Insurance Group Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	QBE discloses a structured governance process that links its climate strategy to both direct and indirect advocacy activities. It explains that “our climate change strategy and policy-related engagement is led by our Group Corporate Affairs and Sustainability function” and that a “Sustainability Governance Framework … ensures engagement activities are consistent with our overall climate change strategy.” Before any public positions are taken, “QBE undertakes an extensive validation process … presented to our ESG Risk Committee or … escalated to the Environmental & Social Group Executive Committee Sub-Committee,” whose chair is the Group Executive of Corporate Affairs and Sustainability and whose members include the Group Chief Risk Officer and Group Chief Underwriting Officer, illustrating a clear approval and oversight pathway. The company identifies concrete channels for both direct lobbying—“The majority of direct external engagement activities are co-ordinated through the Group Corporate Affairs and Sustainability function… our Government Relations & Industry Affairs team… engage with policy makers … consistent with our climate commitments”—and indirect lobbying, noting that “QBE seeks to influence through advocacy, either directly or through industry alliances” and that it “continued our active involvement in the ICA’s Climate & Resilience Committee and Net Zero Working Group.” Named governance bodies (“ESG Risk Committee,” “Executive Risk Committee,” “GEC Environmental and Social sub-committee”) are explicitly tasked to “review ESG business policies and strategies, including climate-related policy positions, and provide recommendations for approval,” indicating ongoing monitoring rather than ad-hoc sign-off. While this demonstrates strong governance—clear responsible committees, a validation and escalation process, and application to both company and trade-association advocacy—the disclosures do not mention a standalone public climate-lobbying alignment report or an external audit of lobbying positions, and there is no stated mechanism for remedial action such as pausing or exiting misaligned associations. Consequently, the company shows robust but not comprehensive governance of its climate-related lobbying activities. View Sources	B

Overall Assessment

Analysis

Score

Strong

QBE discloses a structured governance process that links its climate strategy to both direct and indirect advocacy activities. It explains that “our climate change strategy and policy-related engagement is led by our Group Corporate Affairs and Sustainability function” and that a “Sustainability Governance Framework … ensures engagement activities are consistent with our overall climate change strategy.” Before any public positions are taken, “QBE undertakes an extensive validation process … presented to our ESG Risk Committee or … escalated to the Environmental & Social Group Executive Committee Sub-Committee,” whose chair is the Group Executive of Corporate Affairs and Sustainability and whose members include the Group Chief Risk Officer and Group Chief Underwriting Officer, illustrating a clear approval and oversight pathway. The company identifies concrete channels for both direct lobbying—“The majority of direct external engagement activities are co-ordinated through the Group Corporate Affairs and Sustainability function… our Government Relations & Industry Affairs team… engage with policy makers … consistent with our climate commitments”—and indirect lobbying, noting that “QBE seeks to influence through advocacy, either directly or through industry alliances” and that it “continued our active involvement in the ICA’s Climate & Resilience Committee and Net Zero Working Group.” Named governance bodies (“ESG Risk Committee,” “Executive Risk Committee,” “GEC Environmental and Social sub-committee”) are explicitly tasked to “review ESG business policies and strategies, including climate-related policy positions, and provide recommendations for approval,” indicating ongoing monitoring rather than ad-hoc sign-off. While this demonstrates strong governance—clear responsible committees, a validation and escalation process, and application to both company and trade-association advocacy—the disclosures do not mention a standalone public climate-lobbying alignment report or an external audit of lobbying positions, and there is no stated mechanism for remedial action such as pausing or exiting misaligned associations. Consequently, the company shows robust but not comprehensive governance of its climate-related lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	QBE Insurance Group provides a highly transparent picture of its climate-policy advocacy. It names a wide range of identifiable measures it has engaged on, including the European Insurance and Occupational Pensions Authority’s exercise on the “Prudential Treatment of Climate-Related Adaptation Measures in Non-Life Insurance,” consultations on “mandatory climate-related financial disclosures” with the New Zealand Ministries for Environment and for Business, the draft “IFRS S1 General Requirements” and “IFRS S2 Climate-related Disclosures” being considered by the International Sustainability Standards Board and the Australian Accounting Standards Board, Singapore’s forthcoming “Future Environmental Risk Guidelines,” the Australian Government’s Bushfire Royal Commission recommendations, and the Cyclone Reinsurance Pool legislation examined by the Joint Select Committee on Northern Australia. For each of these policies it discloses concrete channels and targets of engagement: it “responded to EIOPA’s data request” through the National Bank of Belgium, “took part in the consultation” run by the New Zealand ministries, “provided feedback to the Australian Accounting Standards Board,” delivered a presentation to the Monetary Authority of Singapore, and appeared at a public hearing of the Australian Parliamentary inquiry, as well as contributing positions through the Insurance Council of Australia. QBE also states the specific outcomes it seeks. It aimed to determine whether distinct prudential treatment is justified for business that incorporates climate-adaptation measures, supports the introduction of “mandatory climate-related financial disclosures,” backs an Australian “science-based emissions reduction target for 2035” and broader policies to accelerate the transition to net-zero, and presses for “greater investment in the mitigation of both public infrastructure and private household level natural hazard risks,” “improved land use planning,” and “appropriate building codes.” By clearly identifying the policies, the mechanisms and targets of its advocacy, and the detailed policy changes it wants to see, the company demonstrates a comprehensive level of transparency regarding its climate-related lobbying activities.	A