HSBC Holdings PLC

Sign up to access all our data and the evidence and analysis underlying our overall scores. Once you've created an account, we'll get in touch with further details:

Sign Up

Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	HSBC provides an unusually detailed picture of its climate-policy advocacy. It identifies a wide range of concrete policy files it has worked on, including the EU sustainable finance taxonomy and related product standards, the European Union’s Carbon Border Adjustment Mechanism (CBAM), the Bank of England-convened Climate Financial Risk Forum, the Monetary Authority of Singapore’s environmental-risk guidelines, Bank Negara Malaysia’s “Value-Based Intermediation Impact Assessment Framework,” and the Asian Development Bank’s Energy Transition Mechanism to retire coal assets. The bank is equally explicit about how and where it intervenes: it describes “direct engagement with European Commission officials, Members of the European Parliament and representatives of EU Member States through position statements and consultations”; notes that its executives hold “informal meetings with relevant civil servants and UK Government Departments – HM Treasury, BEIS and DEFRA”; and highlights roles such as “Chair of the Financial Centre Advisory Panel (FCAP) work-group set up by MAS,” chair of working groups under the Bank of England’s CFRF, and co-chair of the AFME Sustainable Finance Steer Co. Finally, HSBC states the policy changes it is seeking, backing “a globally-applicable labelling system for sustainable infrastructure assets,” calling for “mandatory net-zero transition plans and climate reporting for enterprises by 2024,” supporting the “phase-out of fossil-fuel subsidies and pricing carbon emissions,” and helping national authorities design frameworks to measure and disclose climate risk. By naming the policies, the channels of influence, the government targets, and the specific outcomes it wants to see adopted, HSBC demonstrates a high level of transparency in its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	HSBC references climate lobbying governance only through a commitment to “Publish a Paris-aligned climate lobbying position, consistent with an overall net zero outcome.” It further confirms its public commitment to conduct engagement activities in line with the Paris Agreement by responding “Yes” to the question “Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?” While this indicates an intention to align its lobbying with climate objectives, the company does not disclose any process for reviewing or monitoring its climate lobbying activities, nor identify a specific individual or formal body responsible for overseeing lobbying alignment, and we found no evidence of mechanisms to ensure both direct and indirect lobbying positions are managed against its climate commitments.	1