Baloise Holding AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Baloise Holding AG demonstrates a moderate level of governance in its lobbying activities, particularly in the context of responsible investment and sustainability. The company has established a comprehensive governance structure, including the Active Ownership Council (AOC), which is responsible for verifying compliance with predefined criteria and making decisions regarding direct corporate dialogues. The AOC includes representatives from Portfolio Management, Compliance, Risk Management, and the Responsible Investment (RI) Team, ensuring interdisciplinary oversight. The Engagement Manager plays a central role in executing the active ownership strategy, including conducting corporate dialogues and preparing Active Ownership Reports, and regularly reports to the AOC, RI Team, Executive Committee, and Insurance Investment Committee (IIC). The company also engages in public policy through memberships in industry associations such as the Swiss Insurance Association (SIA) and Swiss Sustainable Finance (SSF), and participates in working groups that provide feedback on regulatory proposals, such as those from the Swiss Financial Market Authority (FINMA). However, while the governance framework is detailed for responsible investment and sustainability, there is limited explicit disclosure on how lobbying activities, both direct and indirect, are aligned with climate-related goals or the Paris Agreement. The company does not disclose a specific process for monitoring or managing climate lobbying alignment, nor does it provide evidence of a dedicated climate-lobbying audit or review. Additionally, while the Board of Directors and its Strategy and Governance Committee oversee sustainability governance, there is no clear indication that this oversight extends specifically to climate lobbying activities. This indicates a governance framework that addresses sustainability broadly but lacks specific mechanisms for ensuring alignment in climate-related lobbying. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Baloise Holding AG demonstrates a moderate level of governance in its lobbying activities, particularly in the context of responsible investment and sustainability. The company has established a comprehensive governance structure, including the Active Ownership Council (AOC), which is responsible for verifying compliance with predefined criteria and making decisions regarding direct corporate dialogues. The AOC includes representatives from Portfolio Management, Compliance, Risk Management, and the Responsible Investment (RI) Team, ensuring interdisciplinary oversight. The Engagement Manager plays a central role in executing the active ownership strategy, including conducting corporate dialogues and preparing Active Ownership Reports, and regularly reports to the AOC, RI Team, Executive Committee, and Insurance Investment Committee (IIC). The company also engages in public policy through memberships in industry associations such as the Swiss Insurance Association (SIA) and Swiss Sustainable Finance (SSF), and participates in working groups that provide feedback on regulatory proposals, such as those from the Swiss Financial Market Authority (FINMA). However, while the governance framework is detailed for responsible investment and sustainability, there is limited explicit disclosure on how lobbying activities, both direct and indirect, are aligned with climate-related goals or the Paris Agreement. The company does not disclose a specific process for monitoring or managing climate lobbying alignment, nor does it provide evidence of a dedicated climate-lobbying audit or review. Additionally, while the Board of Directors and its Strategy and Governance Committee oversee sustainability governance, there is no clear indication that this oversight extends specifically to climate lobbying activities. This indicates a governance framework that addresses sustainability broadly but lacks specific mechanisms for ensuring alignment in climate-related lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Baloise provides a transparent account of its approach to climate lobbying by clearly outlining the mechanisms it uses and the outcomes it pursues, though it names only one specific regulatory instrument. The company discloses direct and collaborative engagement, participation in working groups such as the Sustainability Commission of the Swiss Insurance Association and the Expert Panel on Climate Risks of the Swiss Financial Market Authority, co-signing letters to the US Securities and Exchange Commission, and contributing to policy consultations (“we respond regularly to policy consultations on ESG topics”). It identifies targets including the SEC, the Swiss Financial Market Authority, and the State Secretariat for International Financial Matters, as well as investor platforms such as Climate Action 100+. While the SEC’s draft climate-disclosure rule is the sole explicitly named policy engagement, Baloise articulates clear objectives for its efforts, including securing TCFD-based, sector-specific metrics and comprehensive greenhouse gas reporting under SEC rules, promoting harmonization of sustainability reporting standards (including through ISSB adoption), and supporting corporate net-zero emission commitments by 2050. These disclosures reflect a comprehensive understanding of its lobbying processes and a clear articulation of its desired policy outcomes.	B