Bangkok Bank PCL

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Bangkok Bank provides a reasonable level of transparency about the climate-related policy issues it engages on. It names several identifiable frameworks or initiatives it has helped shape, including the Industry Handbook on Internalising Environmental and Climate Change Aspects into Financial Institution Business for Banks that was developed in response to Bank of Thailand guidance, the Thai Bankers’ Association ESG Declaration signed in 2022, and the Bangkok Goals on Bio-Circular-Green Economy pledge endorsed by the 2022 APEC Leaders’ Summit, as well as broader support for the Thai government’s BCG economy strategy. The bank also explains the channels it uses to influence policy: senior executives sit on the Climate Change Sub-Working Group of the Joint Standing Committee on Commerce, Industry and Banking, take part in the Sustainability Working Group of the Thai Bankers’ Association, and participate in other committees that provide recommendations directly to the Bank of Thailand and other government agencies. These disclosures identify multiple mechanisms and at least one concrete policymaking target, although most government targets are described generically as “government agencies.” On intended outcomes, the bank states that its advocacy is aimed at helping Thailand achieve net-zero emissions and carbon neutrality by 2050, at encouraging renewable-energy investment and at embedding environmental and climate factors into banking supervision, but it does not set out specific legislative amendments or measurable policy changes it wishes to see. Overall, the information gives a moderate yet incomplete picture of the bank’s climate lobbying activities.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Bangkok Bank PCL’s disclosures provide limited evidence of a lobbying governance process. The bank states "We do not support and are not directly or indirectly involved in any activity related to lobbyists, political contributions, political parties, political candidates, or political influencers," indicating an absence of direct lobbying efforts, and any participation in committees or business networks for policy recommendations is subject only to high-level sign-off, as "participation as a member of business networks or associations must be approved by the Board of Directors through a consideration of objectives and activities of business networks or associations to be in alignment with the Bank’s goals, policies and business conduct." While this approach gives the Board oversight of membership decisions, the bank does not disclose any structured process for monitoring or managing lobbying alignment—direct or through trade associations—nor does it identify a dedicated individual or committee charged specifically with reviewing lobbying positions. We found no evidence of formal lobbying policy enforcement mechanisms or ongoing association review criteria, reflecting the limited scope of governance around policy engagement activities.	1