NN Group NV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	NN Group discloses a basic governance structure that connects its climate-related strategy with its policy-engagement activities but provides limited detail on how lobbying alignment is actively monitored. The company states that “The Corporate Citizenship team of NN Group, under the responsibility of Management Board's Chief Organization & Corporate Relation, is responsible for the consistency of the overall sustainability strategy including climate change” and that these senior representatives sit on internal bodies such as “the NN ESG Policy Committee” to ensure a “consistent approach” across engagement activities, which indicates the existence of an internal process meant to align external advocacy with climate objectives. Oversight is further clarified by the disclosure that “NN Group has a dedicated Public and Government Affairs (PGA) team. The PGA team reports to Director Corporate Relations and to the responsible Member of the Management Board NN Group (Chief People, Communications, and Sustainability Officer),” demonstrating that a named management-board member receives regular reporting on lobbying matters. The Annual General Meeting minutes add that the company lobbies “through associations like the Verbond van Verzekeraars … and other European groups like Insurance Europe” and that “there is always alignment and involvement on the important topics” with a commitment that “NN will continue to report on this,” suggesting some attention to indirect lobbying alignment, although no criteria or formal review mechanism is described. We found no evidence of a publicly available lobbying-alignment audit, no explicit procedure for assessing trade-association positions, and no description of corrective actions (such as escalation or withdrawal) when misalignments occur. Therefore, while NN Group identifies responsible teams and a high-level process linking climate strategy to engagement, the disclosure lacks granular monitoring methods, board-approved review cycles, or detailed outcomes, indicating only moderate transparency and control over climate-related lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

NN Group discloses a basic governance structure that connects its climate-related strategy with its policy-engagement activities but provides limited detail on how lobbying alignment is actively monitored. The company states that “The Corporate Citizenship team of NN Group, under the responsibility of Management Board's Chief Organization & Corporate Relation, is responsible for the consistency of the overall sustainability strategy including climate change” and that these senior representatives sit on internal bodies such as “the NN ESG Policy Committee” to ensure a “consistent approach” across engagement activities, which indicates the existence of an internal process meant to align external advocacy with climate objectives. Oversight is further clarified by the disclosure that “NN Group has a dedicated Public and Government Affairs (PGA) team. The PGA team reports to Director Corporate Relations and to the responsible Member of the Management Board NN Group (Chief People, Communications, and Sustainability Officer),” demonstrating that a named management-board member receives regular reporting on lobbying matters. The Annual General Meeting minutes add that the company lobbies “through associations like the Verbond van Verzekeraars … and other European groups like Insurance Europe” and that “there is always alignment and involvement on the important topics” with a commitment that “NN will continue to report on this,” suggesting some attention to indirect lobbying alignment, although no criteria or formal review mechanism is described. We found no evidence of a publicly available lobbying-alignment audit, no explicit procedure for assessing trade-association positions, and no description of corrective actions (such as escalation or withdrawal) when misalignments occur. Therefore, while NN Group identifies responsible teams and a high-level process linking climate strategy to engagement, the disclosure lacks granular monitoring methods, board-approved review cycles, or detailed outcomes, indicating only moderate transparency and control over climate-related lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	NN Group NV gives a highly transparent picture of its climate-policy lobbying. It identifies a broad suite of specific measures it has engaged on, including the Dutch Climate Agreement, EU Sustainable Finance files such as the Taxonomy Regulation, SFDR and CSRD, reforms to Solvency II, and country-specific forest-protection legislation in Indonesia and Brazil, as well as its input to the European Commission’s Climate Resilience Dialogue and the World Economic Forum’s Climate Adaptation framework. The company also sets out the channels it uses and the actors it targets. It notes that it works “directly with authorities and public decision-makers” through meetings with the Dutch Ministries of Finance and of Climate and Environment, issues investor letters to Indonesian authorities and Brazilian embassies that led to talks with members of the Brazilian Congress, and participates in structured dialogues and working groups. Alongside this direct outreach it lobbies indirectly through bodies such as the Dutch Association of Insurers, Insurance Europe, the Pan-European Insurance Forum and multi-stakeholder platforms like Climate Action 100+, and it discloses its presence in the EU Transparency Register. The mechanisms cited range from phone calls, formal letters and in-person meetings to collective statements and membership of technical working groups. NN Group is equally explicit about what it wants to achieve. It supports the Dutch target of cutting national greenhouse-gas emissions 49 % by 2030, pledges to measure and disclose the carbon footprint of its investments to steer finance toward the energy transition, contributes to EU and international work on climate-adaptation standards for the insurance industry, and seeks “legislation supporting forest and peatland conservation, as well as human rights and Indigenous land rights” and “mechanisms to end deforestation in the Cerrado region.” By naming the policies, describing the engagement routes and specifying the outcomes it is advocating, NN Group provides a comprehensive and detailed account of its climate-related lobbying activities.	A