MBank SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	mBank discloses that decisions on policy engagement are channelled through its sustainability governance structure, stating that “we have established an ESG management system, with key decisions being made by relevant bodies, such as [the] Sustainable Development Committee of mBank Group or our Management Board” and that this system “covers key ESG partnerships, including those which may have influence on public policy.” The Sustainable Development Committee, “chaired by the Vice-President of the Management Board, Chief Risk Officer,” is described as a body that “issues decisions and recommendations regarding ESG policies and guidelines” and “coordinates the work of various organisational units of mBank Group,” while “every quarter, mBank’s Management Board discusses ESG topics with the Supervisory Board.” Operational responsibility sits with “mBank’s ESG team, which is at the same time responsible for effecting our ESG strategy,” indicating a named structure that monitors engagement activities. The bank also notes that “the application for joining the organisation and for paying membership fees is checked and registered each time,” suggesting at least a basic review of indirect affiliations. However, the disclosures are high-level: there is no description of specific criteria or methodology for assessing whether direct lobbying positions or trade-association advocacy align with the bank’s climate targets, no reference to publishing an external lobby-alignment review, and the bank admits it has “No” public commitment “to conduct engagement activities in line with the goals of the Paris Agreement.” Consequently, while a governance framework and responsible committees are identified, the company does not disclose how it systematically tests, corrects or reports on the climate-alignment of either its own advocacy or that of its industry partners, leaving the process largely undefined beyond general ESG oversight. View Sources	C

Overall Assessment

Analysis

Score

Moderate

mBank discloses that decisions on policy engagement are channelled through its sustainability governance structure, stating that “we have established an ESG management system, with key decisions being made by relevant bodies, such as [the] Sustainable Development Committee of mBank Group or our Management Board” and that this system “covers key ESG partnerships, including those which may have influence on public policy.” The Sustainable Development Committee, “chaired by the Vice-President of the Management Board, Chief Risk Officer,” is described as a body that “issues decisions and recommendations regarding ESG policies and guidelines” and “coordinates the work of various organisational units of mBank Group,” while “every quarter, mBank’s Management Board discusses ESG topics with the Supervisory Board.” Operational responsibility sits with “mBank’s ESG team, which is at the same time responsible for effecting our ESG strategy,” indicating a named structure that monitors engagement activities. The bank also notes that “the application for joining the organisation and for paying membership fees is checked and registered each time,” suggesting at least a basic review of indirect affiliations. However, the disclosures are high-level: there is no description of specific criteria or methodology for assessing whether direct lobbying positions or trade-association advocacy align with the bank’s climate targets, no reference to publishing an external lobby-alignment review, and the bank admits it has “No” public commitment “to conduct engagement activities in line with the goals of the Paris Agreement.” Consequently, while a governance framework and responsible committees are identified, the company does not disclose how it systematically tests, corrects or reports on the climate-alignment of either its own advocacy or that of its industry partners, leaving the process largely undefined beyond general ESG oversight.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E