Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Limited |
Banco Comercial Portugues discloses a high-level commitment to keep its external engagements consistent with its climate goals but provides little detail on how lobbying itself is governed. It states that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and explains that it “promotes climate change and public awareness through several ways” while describing processes “to ensure that your external engagement activities are consistent with your climate commitments.” Oversight of sustainability more broadly is assigned to multiple bodies – the “Sustainability Commission, that emanates from the Executive Committee and is chaired by the CEO,” which is “responsible for the appraisal, discussion and supervision of the implementation of the organization-wide sustainability strategy,” and sustainability matters are “supervised by the Board of Directors … supported by the Committee for Corporate Governance, Ethics and Sustainability.” However, the disclosure focuses on general ESG strategy and climate-related products rather than on political engagement; it does not describe how lobbying positions are approved or monitored, does not mention any review of trade-association advocacy, and does not identify controls that would align direct or indirect lobbying with its Paris commitments. Consequently, while the company signals an intention to align engagement with climate objectives and names senior oversight bodies, it does not disclose a specific governance process for lobbying alignment, indicating only limited transparency on this topic.
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D |