Santander Bank Polska SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Santander Bank Polska SA outlines extensive sustainability governance bodies, noting that "The Responsible Banking and Organisational Culture Committee of Santander Bank Polska ... assists the Bank’s Management Board in fulfilling its oversight responsibilities with respect to the responsible business strategy and sustainability issues" and that its standing committees include a "Public Policy Committee". However, we found no evidence of any policy or process that governs direct or indirect lobbying activities, no description of how lobbying is monitored or aligned with climate or corporate policy, and no specific individual or committee charged with oversight of lobbying efforts. This indicates that while the bank has robust structures for risk and sustainability management, it does not disclose a lobbying governance framework. View Sources	0

Overall Assessment

Analysis

Score

None

Santander Bank Polska SA outlines extensive sustainability governance bodies, noting that "The Responsible Banking and Organisational Culture Committee of Santander Bank Polska ... assists the Bank’s Management Board in fulfilling its oversight responsibilities with respect to the responsible business strategy and sustainability issues" and that its standing committees include a "Public Policy Committee". However, we found no evidence of any policy or process that governs direct or indirect lobbying activities, no description of how lobbying is monitored or aligned with climate or corporate policy, and no specific individual or committee charged with oversight of lobbying efforts. This indicates that while the bank has robust structures for risk and sustainability management, it does not disclose a lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Santander Bank Polska provides only limited insight into its climate-related lobbying. It refers in broad terms to engagement on the European Green Deal through the Green Transformation Council of the Lewiatan Confederation and to alignment with international frameworks, but it does not name any specific laws, bills or regulatory proposals it has sought to influence. The only mechanism it identifies is indirect participation in that industry body and what it calls “active cooperation with public administration,” without stating whether this involves meetings, letters, consultations or which ministries or officials are approached. Likewise, the bank discloses no concrete public-policy outcomes it aims to secure; it focuses instead on internal objectives such as phasing out financing for thermal-coal clients by 2030 and achieving net-zero emissions by 2050. Because the disclosures stop short of specifying the public policies, lobbying channels, or legislative changes the Group supports or opposes, the level of transparency remains low.	1