Muenchener Rueckversicherungs-Gesellschaft AG in Muenchen

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Munich Re discloses a solid amount of detail on its climate-policy lobbying. It identifies several concrete policy arenas it has worked on, including the German Government’s Sustainable Finance Strategy through its seat on the official Sustainable Finance Committee, the EU Sustainable Finance Regulation, and broader ‘regulation on climate risks’, while also situating its advocacy within UNFCCC negotiations. The company explains how it seeks to influence these files, citing participation in public consultations and supervisory-authority surveys, formal representation on the government advisory committee, public statements and press conferences (e.g. at COP26), and indirect work through trade associations listed in both the EU Transparency Register and the German Bundestag lobby register. Most importantly, Munich Re is explicit about the outcomes it wants: it calls for “a sufficiently high CO2 price of more than US$100 per tonne by 2030” implemented via “comprehensive trading systems with a fixed target of ‘net-zero’ emissions by 2050,” supports an interim CO2 tax with revenues “redistributed to low-income persons,” and urges European policymakers to “introduce a meaningful price on carbon emissions that create financial incentives to accelerate the switch from fossil fuel to renewables.” By combining clear descriptions of the policies it addresses, the channels it uses, and the specific legislative or regulatory changes it seeks, the company demonstrates a strong level of transparency around its climate-related lobbying activity.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Munich Re has established organizational and oversight structures to align its lobbying with its climate change strategy, though it stops short of a dedicated climate lobbying governance framework. The company explains that “both, the Sustainability and the Public Affairs team, are in the same division and report to the same person (Munich Re's Chief Economist and Head of Economics, Sustainability & Public Affairs),” which it says provides “alignment from an organisational perspective,” and notes that issues are “discussed in the Group Lobbying Committee on a regular basis in order to make sure that our policies, including our climate change strategy, are distributed Group-wide.” This indicates a formal process and a named oversight body, but Munich Re “has no public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and “do not plan to have one in the next two years,” reflecting an absence of explicit climate-focused lobbying commitments. While the Public Affairs department “is responsible for the Munich Re Group’s lobbying” and discloses its activities in various transparency registers, the company does not disclose specific procedures for aligning its direct advocacy or trade association memberships with its climate commitments or any criteria for assessing conflicting positions, suggesting that its oversight remains broad rather than climate-specific in its governance of lobbying efforts.	2