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| Overall Assessment |
Analysis |
Score |
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None
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Hong Kong Exchanges & Clearing Ltd demonstrates a comprehensive ESG and sustainability governance framework—“The HKEX Board of Directors monitors the Group’s operating, financial and ESG performance, reviews the Group’s compensation policies and succession planning, and ensures that a positive and progressive culture, effective ESG policies, and appropriate and effective internal control and risk management systems are in place” and “takes on the overall responsibility for overseeing and reviewing the Group’s sustainability strategy, including climate-related risks and opportunities, and their respective policies.” The Board has delegated oversight to a Corporate Responsibility Committee, “delegated by the Board to oversee matters concerning the CR management framework and policies,” and in 2024 established an Executive Corporate Responsibility Committee “co-chaired by the Chief Executive Officer and the Group Chief Sustainability Officer” to manage CR matters. However, we found no evidence of any governance process or oversight related to lobbying activities—no policy, review mechanism, or individual or committee tasked with monitoring, managing, or aligning direct or indirect lobbying or policy advocacy with climate or broader company objectives.
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E
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| Overall Assessment |
Analysis |
Score |
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Limited
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Hong Kong Exchanges & Clearing Ltd gives only a basic outline of its climate-policy engagement. It refers to working on climate-related disclosures and carbon-market initiatives but does not name any specific laws or regulations it has tried to influence; the most detailed reference is a consultation on “mandatory climate disclosures” that would align with the IFRS S2 standard, which is described without a bill number or regulatory citation. The company indicates some means of engagement, citing actions such as “launching consultations” and collaborating with bodies like the Hong Kong Green and Sustainable Finance Cross-Agency Steering Group, yet it does not spell out concrete mechanisms such as meetings, letters or submissions to particular ministries or legislators, nor does it identify the individual agencies or officials targeted. Likewise, the outcomes it seeks remain broad: it wants to “facilitate effective and transparent trading of carbon credits,” “support the global transition to Net Zero,” and “raise market standards and align reporting taxonomy in Hong Kong,” but it does not translate these aspirations into clearly defined policy changes, thresholds or timelines. Taken together, the disclosures show limited transparency about the substance, methods and objectives of the company’s climate-related lobbying.
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D
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