BNP Paribas SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	BNP Paribas discloses an extensive and specific picture of its climate-policy lobbying. It names multiple regulations and legislative files it has engaged on, including the “Taxonomy Regulation Article 8 Draft Delegated Act”, the EU Sustainable Finance Regulation, the Corporate Sustainability Reporting Directive and SFDR package, France’s mandatory GHG-reporting rules and SRI label developed after the 2014 “State conference on financing energy transition”, as well as global processes such as COP21 and the Paris Agreement and calls for “carbon pricing” and the “phasing out of fossil-fuel subsidies”. The bank also describes a range of concrete lobbying channels and the policy-making audiences it targets: its chairman co-signed proposals from AFEP, Cercle de l’Industrie and MEDEF to influence the COP21 negotiations; the CEO joined an IIGCC letter lobbying G7 finance ministers; it filed a formal response to the European Commission consultation on the Taxonomy Article 8 rules; it sat on the Commission’s High-Level Expert Group on Sustainable Finance; and it held follow-up meetings with the French Government after the national conference on financing the energy transition, while routinely briefing French parliamentarians and being listed on EU, French, German and US lobbying registers. Finally, BNP Paribas is explicit about what it wants to achieve: it advocates a “carefully considered phased-in approach for introducing reporting requirements” under the Taxonomy, alignment of KPI calculations with the EBA’s Green Asset Ratio, a “long-term global emissions reduction goal” in the Paris Agreement backed by intermediate national pledges, the introduction of mandatory GHG reporting in France, creation of an SRI label, a prompt and effective carbon price, and support for the Green Supporting Factor to speed green lending. This level of detail on the policies addressed, the tools used and the outcomes pursued demonstrates comprehensive transparency in the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	BNP Paribas demonstrates a moderate level of governance in its lobbying activities, with some processes and oversight mechanisms disclosed. The company has adopted a “Charter for responsible representation with respect to the public authorities,” which applies to all employees and includes commitments to integrity, transparency, and social responsibility. It has established the Institutional Affairs Department (DAI) to ensure the consistency and integrity of its stances with public authorities and compliance with the Charter. The DAI coordinates several committees and oversees first-level controls of interest representation activities, while second- and third-level controls are conducted by the Group’s Compliance and Inspection Générale departments. Employees are required to obtain authorization from their superiors before engaging in public representation activities and must report their activities to the Public Affairs Department. However, while these measures indicate governance of lobbying activities, there is limited evidence of specific processes to align lobbying with climate-related goals. The company mentions its commitment to the Paris Agreement and its strengthened governance in sustainable finance, including the creation of committees such as the Sustainable Finance Strategic Committee and ESG Regulatory Committee, but these disclosures focus more on ESG and sustainable finance governance rather than direct or indirect lobbying alignment with climate goals. Additionally, while BNP Paribas has processes for monitoring and exclusion lists in its investment and asset management activities, these are not explicitly tied to lobbying governance. The company does not disclose a detailed process for reviewing or managing lobbying alignment with climate goals, nor does it provide evidence of engaging with or exiting trade associations based on climate policy alignment.	2