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| Overall Assessment |
Analysis |
Score |
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None
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Swedbank AB describes its engagement tactics but does not disclose an internal governance process for ensuring its lobbying is aligned with its climate strategy. It states that it “endeavor[s] to be present and visible at events where relevant policy or decision makers are also present” and that it conducts “investor letter writing campaigns directed towards policy makers,” but it does not detail any policy, oversight body, review mechanism, or named individual responsible for monitoring or approving these activities. We found no evidence of procedures to ensure consistency with its overall climate change strategy, no criteria for assessing its participation in associations, and no transparency on how direct or indirect lobbying is governed, indicating a lack of transparency in its lobbying governance.
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E
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| Overall Assessment |
Analysis |
Score |
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Limited
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Swedbank AB provides limited transparency on its climate-related lobbying. It outlines participation in forums and panel discussions—such as the “New Economy Forum on Global Finance and Green Transition in Hong Kong” and a “PRI Nordic panel discussion on net zero target setting”—but does not name any government bodies or officials as the targets of these engagements. The bank mentions taking part in statements including “PRI recommendations to the SEC on corporate climate disclosure” and the “IIGCC Global Investor Statement to Governments on the climate crises,” yet omits clear identification of the policymakers or agencies it addressed. While Swedbank indicates engagement with policy areas like EU and US sustainability reporting, adaptation and resilience, and circular economy, it does not specify any particular legislation or regulation. It further notes its alignment with the Paris Agreement but refrains from outlining any concrete policy outcomes, legislative changes, or measurable targets. As a result, the disclosures provide only a broad overview of engagement themes without sufficient detail on the specific policies, mechanisms, and outcomes the bank pursued.
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D
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