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Bank of Communications Co Ltd’s disclosures focus on climate risk and green finance governance with robust board-level oversight, but contain no mention of any internal process for overseeing its lobbying activities or aligning them with its climate policy. The company details that “The Board of Directors undertakes ultimate responsibility for business management as the top decision-making body for the Bank's risk management and green finance,” and that it has established a “Green Finance Management Committee (GFMC)” that “monitors and supervises the Bank's green finance management, and also collectively reviews and evaluates the various objectives, action plans, as well as major issues and topics related to environmental, social and governance risks” through regular or irregular meetings, alongside a “Risk Management Committee (RMC)” that is “responsible for monitoring various risks, including but not limited to ... climate risk.” The Senior Management further “regularly reports the project progress to the Board of Directors and board-level committees to assist in evaluating climate-related management performance.” However, we found no evidence the company discloses any mechanism, designated individual, or committee that oversees its lobbying activities—direct or indirect—or any process to ensure its policy advocacy is aligned with its climate-related objectives.
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