Bank of Montreal

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Bank of Montreal provides a mixed but improving picture of transparency around its climate-policy lobbying. The bank discloses individual examples of engagement, such as supporting an open letter urging EU leaders to align post-pandemic recovery plans with the EU Green Deal, writing to the UK electricity regulator Ofgem in favour of greater grid investment for zero-carbon power, and signing a letter to the South Korean government calling for limits on overseas coal-plant finance. These references show that the bank is willing to name some of the climate-policy areas it addresses, although it does not consistently list or describe the full set of specific laws or regulations it targets. It is more explicit on how it lobbies: it describes collaborative letters, policy statements developed through groups like the Institutional Investors Group on Climate Change, and the filing of federal lobbying disclosure reports in both Canada and the United States; it also confirms direct engagement, noting that it has met with “US and Canadian government regulators to discuss climate-related topics, as part of regular meetings and touchpoints.” Finally, the bank outlines the broad outcomes it seeks—recovery measures consistent with the EU Green Deal, regulatory permission for grid upgrades to enable zero-carbon energy, and restrictions on public finance for new coal projects—demonstrating clear positions even if it rarely provides granular targets or legislative text. Overall, the disclosures offer moderate transparency: mechanisms and high-level objectives are described in detail, but the list of individual climate policies engaged remains limited.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Bank of Montreal has implemented processes to govern its climate-related engagement, but it does not disclose a fully comprehensive lobbying alignment framework. For example, the bank explains that “Only authorized BMO representatives knowledgeable of climate strategy are involved in climate related engagement with stakeholders or policy makers,” and notes that “BMO’s Sustainability Council…are kept apprised of climate strategy matters through quarterly Sustainability Council meetings, including any engagement opportunities,” which demonstrates a defined mechanism to ensure direct lobbying aligns with its climate objectives. It is also stated that “Our Government Relations team manages lobbying activity and tracks our engagement with public officials,” suggesting procedural oversight of its general policy advocacy. However, we found no evidence of how indirect lobbying—such as through trade or industry associations—is monitored for climate alignment, nor does the bank disclose a board-level sign-off process, a dedicated climate-lobbying review or audit, or specific criteria for evaluating the consistency of all lobbying activities with its climate strategy. While roles like the General Counsel and sustainability committees are clearly defined within its broader sustainability governance, their connection to managing and aligning lobbying efforts on climate issues is not explicitly disclosed, indicating moderate but incomplete oversight of climate lobbying.	2