ABN AMRO Bank NV

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	ABN AMRO gives a detailed picture of which climate-related policy debates it joins. It names a range of identifiable measures, including the “EU taxonomy” and “ESRS/CSRD” corporate-reporting rules, its participation in the “Dutch climate adaptation plan working groups, organised by the Dutch government,” support for the Netherlands’ 2030 zero-emission vehicle mandate and the EU’s 2035 ban on new internal-combustion cars, as well as lobbying at EU level for “bringing financial institutions into scope of the Corporate Sustainability Due Diligence Directive (CS3D).” The bank also explains how it seeks to influence these files: it engages directly by “sharing information formally and informally in writing, one-on-one talks, exchanges with several stakeholders at a time, closed and public consultations and discussions with experts” with “members of the Dutch Parliament, Dutch government ministers and their ministries, the European Parliament, the European Commission and others,” and indirectly through trade bodies such as the Dutch Banking Association (NVB) and the Institute of International Finance (IIF). While it states general positions—such as “support with minor exceptions” for EU reporting standards and alignment of all activity with the Paris Agreement—it rarely sets out precise legislative amendments or numerical targets it is advocating, providing only limited clarity on the specific outcomes it is seeking. Overall, the company is highly transparent about the policies it engages on and the channels and targets of that engagement, but gives less detail on the concrete policy changes it wants to secure.	3

Lobbying Governance

Overall Assessment	Comment	Score
Strong	ABN AMRO discloses a clear governance framework linking its advocacy work to its climate commitments. It states that “a process has therefore been set up to assess whether our own direct lobbying activities, as well as the indirect lobbying activities of the (most relevant) trade organisations of which we are a member, are in line with the Paris Climate Agreement,” demonstrating an explicit mechanism for monitoring both direct and trade-association lobbying. The bank describes escalation measures, noting that when misalignment is found “we will endeavour to adjust the position of that trade association or, if that proves impossible, to publicly address the misalignment and state that the trade association does not represent the views and position of ABN AMRO,” which indicates active management of indirect lobbying. Oversight responsibilities are identified: “The Public Affairs team is made up of two in-house lobbyists… reporting back to the Executive Board and senior management,” providing a named function that monitors activities and a formal body that reviews them. Together with the declaration that “ABN AMRO’s lobbying activities must also be aligned with ‘Paris’,” this points to a structured, climate-specific alignment process. However, the disclosure does not provide detail on the frequency or outcomes of these reviews, nor does it publish a dedicated lobbying-alignment report or third-party audit, so transparency on effectiveness remains limited.	3