Danske Bank A/S

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Danske Bank A/S has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly identifies specific climate policies it has engaged with, such as the "EU regulation on sustainable finance following from the EU Commission's Sustainable Finance Action Plan and its subsequent Renewed Sustainable Finance Strategy," and its contributions to the development of eco-labels for financial products. It also references its alignment with the Paris Agreement and the EU Taxonomy Regulation, providing clear details about its policy engagements. Danske Bank provides detailed information on its lobbying mechanisms, including direct methods such as "letters, e-mails, and meetings (in person or virtually) with the relevant representatives" and indirect mechanisms like "engagements conducted by a third-party on behalf of Danske Bank." Specific targets of its lobbying efforts include "government officials," "Members of Cabinet," "Central Bank," and "State-Owned Enterprises (SOE)," as well as collaborative engagements through initiatives like Climate Action 100+ and Nature Action 100. Furthermore, the company has been explicit about the outcomes it seeks, such as aligning corporate lobbying activities with the climate targets of the Paris Agreement, phasing out investments in thermal coal, tar sands, and peat-fired power generation by 2040, and achieving net-zero greenhouse gas emission investment portfolios by 2050. Danske Bank also advocates for increased transparency in climate-related lobbying, stating, "We voted in favor of proposals urging companies to align their lobbying activities with the climate targets of the Paris Agreement." This level of detail and clarity illustrates Danske Bank's comprehensive approach to disclosing its climate lobbying efforts and objectives. 4
Lobbying Governance
Overall Assessment Comment Score
Strong Danske Bank demonstrates strong governance processes for climate lobbying alignment, with a clearly defined governance structure anchored at the Board of Directors (BoD) and Executive Leadership Team (ELT). The governance framework includes oversight from the Business Integrity Committee, chaired by the CEO, which receives quarterly updates on progress towards climate targets, ensuring senior management engagement and accountability. The alignment of climate lobbying activities is further supported by ongoing dialogue between the Group Sustainability unit and the Group Public Affairs unit, as well as the inclusion of the Head of Group Public Affairs in the Sustainable Finance Council, which advises the Business Integrity Committee. Additionally, the governance structure integrates sustainability into the corporate strategy, with senior management remuneration linked to climate target progress, and includes mandatory annual training for employees on sustainability, risk, and compliance. While the governance framework is robust and includes monitoring mechanisms and accountability structures, the evidence does not indicate the publication of a detailed lobbying audit or annual lobbying report specifically addressing direct and indirect climate lobbying alignment, which would further enhance the governance framework. 3