Standard Bank Group Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Standard Bank Group provides a detailed and wide-ranging picture of its climate-related lobbying. It names numerous identifiable measures it has tried to influence, including the “South Africa Climate Change Bill”, the “Draft Renewable Energy Masterplan”, National Treasury’s “Green Finance Taxonomy” and associated “Draft Sustainable Finance Technical Paper”, the “Conduct of Financial Institutions Bill”, the “UK Parliament Policy Enquiry: UK-Africa Partnerships for Just Energy Transitions”, the “Zimbabwe Climate Risk Management Guideline” and the “climate-change modelling framework for financial stress testing in Southern Africa”. The bank is equally explicit about how and where it lobbies, citing “formal engagements with central banks and other regulatory bodies”, participation in “deliberations in Parliament”, written “submissions on forthcoming policy changes”, bilateral meetings with “National Treasury’s sustainable finance team”, work in the “SARB Prudential Authority Climate Think Tank (PACTT) working group”, and indirect activity through trade bodies such as the Banking Association South Africa and UNEP-FI forums. Finally, it sets out the concrete results it seeks: supporting “more ambitious climate targets in South Africa’s NDCs – greater emission cuts by 2030 and a commitment to net-zero by 2050”, advocating for a global “loss and damage” fund, pushing for the adoption of a green finance taxonomy, and limiting its own financing of standalone gas plants to 0.75 % of advances after 2026 as part of a just energy transition. The combination of clearly identified policies, transparent mechanisms and specific, measurable policy goals demonstrates a comprehensive level of disclosure on the bank’s climate-lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Standard Bank Group has established a policy to govern its indirect lobbying activities through trade associations, defining mandates for representation, requiring internal consultation, and including an “annual review of representatives” to manage consistency across its memberships. As outlined, “Participation in Trade Associations policy aims to ensure: group’s position and representation are managed and consistent across various associations; adequate internal consultation is undertaken to formulate positions; representatives are clearly mandated and supported to communicate bank-wide positions; developments and positions on material issues are appropriately reported to relevant stakeholders, and all representatives conduct themselves in a way that reflects the values and protects the reputation of Standard Bank,” and specifies “criteria for an annual review of representatives.” The group also affirms that “we do not provide funding for lobbying on specific issues,” demonstrating limits on financial contributions. However, the company does not disclose any process that aligns its lobbying activities—direct or indirect—with its climate policy and makes no reference to board or executive oversight of climate-related lobbying. We found no evidence of a defined governance process for aligning or monitoring climate lobbying, including any named individual, committee, or reporting mechanism responsible for that function.	1