CaixaBank SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	CaixaBank discloses a well-defined internal system to keep both its direct advocacy and its trade-association lobbying consistent with its climate commitments, indicating strong governance. The bank states that it "assess[es] the alignment of the position of organisations with which we collaborate, as well as that of our advocacy activities, with objectives of the Paris Agreement and other core values of CaixaBank. In the event of misalignment, mitigating measures are defined and implemented," demonstrating an explicit alignment test and corrective mechanism for indirect lobbying. Direct engagement is handled through the Regulation Committee, which "is responsible for monitoring the regulatory environment and setting positions on developments of public policies that are relevant to the entity and the financial system," and its activities are supervised by named individuals – "the Chief Compliance, Control and Public Affairs Officer (member of the Management Committee) and the Director of Public Affairs." Oversight is further reinforced because "CaixaBank's participation and interaction in meetings with the heads of authorities and supervisors are shared with the members of the Regulatory Committee on a monthly basis," and a 2023 internal audit confirmed that the Committee "fulfils the functions defined in the Committee Governance Standard." For trade-group memberships, the bank notes it has "a rigorous process for assessing any proposal to join an association… [including] an internal reputational risk check to ensure that the association in question is recognised and has a proven reputation and conduct," and emphasises that “positions and communications that reach associations and authorities are consistent with the bank's strategy.” Ultimate accountability sits at board level as "the Board of Directors is responsible for approving, supervising and periodically assessing" the sustainability strategy that encompasses these lobbying rules, and the Appointments and Sustainability Committee "supervis[es] compliance" with the related policies. While these disclosures show clear processes, regular monitoring, and named oversight for both direct and indirect climate-related lobbying, the company does not disclose a standalone public audit or detailed external report evaluating the alignment of each lobbying activity or trade association, so transparency is not yet comprehensive. View Sources	B

Overall Assessment

Analysis

Score

Strong

CaixaBank discloses a well-defined internal system to keep both its direct advocacy and its trade-association lobbying consistent with its climate commitments, indicating strong governance. The bank states that it "assess[es] the alignment of the position of organisations with which we collaborate, as well as that of our advocacy activities, with objectives of the Paris Agreement and other core values of CaixaBank. In the event of misalignment, mitigating measures are defined and implemented," demonstrating an explicit alignment test and corrective mechanism for indirect lobbying. Direct engagement is handled through the Regulation Committee, which "is responsible for monitoring the regulatory environment and setting positions on developments of public policies that are relevant to the entity and the financial system," and its activities are supervised by named individuals – "the Chief Compliance, Control and Public Affairs Officer (member of the Management Committee) and the Director of Public Affairs." Oversight is further reinforced because "CaixaBank's participation and interaction in meetings with the heads of authorities and supervisors are shared with the members of the Regulatory Committee on a monthly basis," and a 2023 internal audit confirmed that the Committee "fulfils the functions defined in the Committee Governance Standard." For trade-group memberships, the bank notes it has "a rigorous process for assessing any proposal to join an association… [including] an internal reputational risk check to ensure that the association in question is recognised and has a proven reputation and conduct," and emphasises that “positions and communications that reach associations and authorities are consistent with the bank's strategy.” Ultimate accountability sits at board level as "the Board of Directors is responsible for approving, supervising and periodically assessing" the sustainability strategy that encompasses these lobbying rules, and the Appointments and Sustainability Committee "supervis[es] compliance" with the related policies. While these disclosures show clear processes, regular monitoring, and named oversight for both direct and indirect climate-related lobbying, the company does not disclose a standalone public audit or detailed external report evaluating the alignment of each lobbying activity or trade association, so transparency is not yet comprehensive.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	CaixaBank provides only a modest level of insight into its climate-policy lobbying. It identifies a handful of concrete policy files it has worked on, such as the European Commission’s initiative “Unlocking Private Investment in Energy Efficiency: guidance for Member States and market actors,” and it notes that its engagement is shaped by frameworks like the EU Taxonomy and the Paris Agreement, but it does not go on to list a broader set of bills, regulations or consultations it has addressed. The bank explains that it normally channels its views “through industry associations” including ESBG, CECA, IIF, WSBI and “occasionally sends direct messages to authorities,” yet it stops short of naming the specific ministries, parliamentary committees or regulators that receive those messages, giving only one clear mechanism (indirect association work) and no clearly identified policymaking targets. On objectives, it speaks in broad terms about securing “a regulatory framework for sustainable finance aligned with the Paris Agreement and the 2030 Agenda,” promoting “environmental taxation,” and supporting a “fair transition,” and it reiterates internal goals such as phasing out thermal-coal financing by 2030, but it does not translate these aspirations into concrete legislative changes or numeric policy outcomes it is pressing governments to adopt. Taken together, the disclosures show limited transparency: some policies and channels are identified, but the detailed mechanisms, specific lobbying targets and clearly defined policy outcomes remain largely unspecified.	D