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| Overall Assessment |
Comment |
Score |
| Comprehensive |
The Commonwealth Bank of Australia (CBA) has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly identified specific climate-related policies and initiatives it has engaged with, such as the Clean Energy Regulator's Corporate Emissions Reductions Transparency (CERT) report pilot, the Australian Prudential Regulation Authority's (APRA) Climate Vulnerability Assessment (CVA), and the development of a sustainable finance taxonomy by ASFI. Additionally, CBA has disclosed its direct engagement with government agencies, including the Net Zero Economy Agency, and its participation in consultations on mandatory climate-related financial disclosures and sectoral decarbonization plans. The company has also detailed its lobbying mechanisms, including engagement through trade associations like the Australian Banking Association (ABA) and the Business Council of Australia, as well as partnerships with organizations like CSIRO to inform climate-related objectives. Furthermore, CBA has articulated specific outcomes sought through its lobbying efforts, such as advocating for mandatory carbon reporting, supporting the development of sectoral decarbonization pathways, and aligning with TCFD recommendations to ensure consistent climate-related financial disclosures. These disclosures reflect a high level of transparency and a clear commitment to influencing climate policy in a structured and accountable manner.
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4
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| Overall Assessment |
Comment |
Score |
| Strong |
The Commonwealth Bank of Australia (CBA) demonstrates a strong governance framework for climate lobbying alignment, supported by its Environmental and Social (E&S) Framework and related mechanisms. The governance process is clearly defined, with oversight structures and accountability measures in place. The Board holds the CEO and Executive Leadership Team (ELT) accountable for delivering E&S responsibilities, with the ELT E&S Committee, chaired by the CEO, meeting monthly to oversee the implementation of the E&S strategy, governance, and disclosures. This committee is further supported by the Business E&S Action Group, chaired by the CFO, which reviews documentation, sets targets, and monitors progress. CBA has established processes for monitoring and managing climate-related lobbying activities, including aligning financed emissions targets with the 1.5°C global temperature goal, and has joined the Net-Zero Banking Alliance (NZBA) to inform its sector-level financed emissions targets. The evidence states, "We are developing sector-level strategies to deliver against these targets while also looking to set additional science-based targets using the transition pathways being developed with CSIRO." Additionally, the bank has implemented a quarterly monitoring process involving the ELT E&S Committee and Business E&S Action Group to track progress against these targets. CBA also reviews its industry associations' policy positions to ensure alignment with its climate stance, stating, "We will establish an annual review process to understand alignment between our position on climate and that of the industry associations in which we are active participants. If a misalignment is identified in the annual review, we will proactively share our position and rationale with the industry association through our participation in relevant forums." While the evidence does not explicitly mention a detailed lobbying audit or comprehensive review of indirect lobbying activities, the governance structures and processes described indicate robust oversight and alignment mechanisms for climate-related lobbying activities, both direct and indirect.
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3
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