Bank of Cyprus Holdings PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Bank of Cyprus has put in place an extensive framework for overseeing ESG and climate-related risks, with its Sustainability Committee “chaired by the Bank’s CEO” that “guides and reviews the development of the Bank’s ESG strategy” and ensures “the implementation of the Group’s ESG & Climate strategy,” supported by the Risk Committee, which is tasked with “identifying, assessing, controlling and monitoring ... ESG including C&E risks” and the Nominations and Corporate Governance Committee that “oversees the Sustainability Committee’s implementation and progress of the ESG working plan.” While these disclosures illustrate a strong governance structure for managing environmental and climate-related risks and objectives, we found no evidence of any governance process for lobbying or policy engagement, whether direct or indirect, nor any mention of oversight mechanisms, review processes, or responsible individuals for ensuring that lobbying activities align with the bank’s climate or broader ESG goals. View Sources	E

Overall Assessment

Analysis

Score

None

Bank of Cyprus has put in place an extensive framework for overseeing ESG and climate-related risks, with its Sustainability Committee “chaired by the Bank’s CEO” that “guides and reviews the development of the Bank’s ESG strategy” and ensures “the implementation of the Group’s ESG & Climate strategy,” supported by the Risk Committee, which is tasked with “identifying, assessing, controlling and monitoring ... ESG including C&E risks” and the Nominations and Corporate Governance Committee that “oversees the Sustainability Committee’s implementation and progress of the ESG working plan.” While these disclosures illustrate a strong governance structure for managing environmental and climate-related risks and objectives, we found no evidence of any governance process for lobbying or policy engagement, whether direct or indirect, nor any mention of oversight mechanisms, review processes, or responsible individuals for ensuring that lobbying activities align with the bank’s climate or broader ESG goals.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Bank of Cyprus Holdings PLC is highly transparent about its climate-related lobbying stance. The company states unambiguously that it undertakes no direct or commissioned lobbying, noting that "Bank of Cyprus does not engage in lobbying and does not commission lobbying services but actively contributes to the public debate through its membership in acclaimed associations and industry bodies." By openly declaring non-engagement, describing the alternative avenue it uses to participate in public debate, and making the same clear statement across the themes of policies addressed, mechanisms employed and outcomes pursued, the bank provides full visibility into its position and activities—namely that it seeks to influence no specific climate policies, employs no lobbying mechanisms, and pursues no lobbying outcomes.	A