Swiss Re AG

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Swiss Re provides a detailed and wide-ranging picture of its climate-policy engagement. It names numerous identifiable measures it works on, including the EU Taxonomy and biodiversity elements of the European Green Deal, the Corporate Sustainability Reporting Directive, the Singapore Taxonomy, Bank Negara Malaysia’s Climate Change Risk Management and Scenario Analysis Policy Document, the Monetary Authority of Singapore Guidelines on Environmental Risk Management, the Task Force on Climate-related Financial Disclosures (TCFD) recommendations and the emerging International Sustainability Standards Board standards, as well as technical work on the European Commission’s climate-transition and Paris-aligned benchmarks. The company also explains how it seeks to influence these initiatives: it “provid[es] input to the European Insurance and Occupational Pensions Authority (EIOPA),” participates in European Commission “focus groups and the Technical Expert Group on Sustainable Finance,” holds “regular dialogue with the National Association of Insurance Commissioners (NAIC),” serves on the MAS Green Finance Industry Taskforce, and channels messages through trade bodies such as the Reinsurance Advisory Board and the Pan-European Insurance Forum. These mechanisms are supplemented by membership-based advocacy, for example the CEO’s co-chairing of the WEF Alliance of CEO Climate Leaders, whose members “will be in person in Glasgow and look forward to discussing with world leaders, government officials and representatives of the NGO community,” and by direct advocacy in publications, roundtables and open consultations. Swiss Re also sets out the concrete policy outcomes it pursues: the Alliance letter urges governments to “publish ambitious and 1.5 °C-aligned Nationally Determined Contributions that at least halve global emissions by 2030… eliminate fossil fuel subsidies… [and] develop market-based meaningful and broadly accepted carbon pricing mechanisms,” while the company itself seeks “convergence and harmonisation of relevant disclosure requirements” through TCFD and ISSB, promotion of green-finance solutions and strengthened environmental-risk management rules. Taken together, these disclosures demonstrate a high level of transparency across the policies lobbied, the channels used, and the results the company wants to see from its climate-related advocacy. 4
Lobbying Governance
Overall Assessment Comment Score
None Swiss Re AG does not disclose any governance processes to align its lobbying activities with its climate commitments. Although it states “Our engagement and dialogue with all our stakeholders is based on trust, mutual respect and integrity and is governed by published governance guidelines such as Swiss Re's Code of Conduct,” it offers no detail on how those guidelines apply to its “advocacy activities in the European Union,” whether carried out “directly or through trade associations.” The evidence focuses on its ESG Risk Framework for underwriting—detailing the “ESG Risk Service,” “ESG Risk Referral Tool” and appeals process—and on board-level sustainability oversight, where the Board and Group Executive Committee “approve sustainability policies” and the Group Sustainability Council “oversees the integration of governance and operational aspects of sustainability”—but none of these disclosures explain a process for reviewing or managing lobbying positions or trade-association memberships against its climate strategy. The description of stakeholder interactions—describing how “our role as a risk knowledge company” and the Swiss Re Institute “play a key role in our dialogue with stakeholders”—emphasizes knowledge exchange rather than formal oversight or accountability structures specific to climate-related advocacy, and there is no named individual or committee tasked with ensuring that lobbying aligns with Swiss Re’s climate commitments. 0