SEB SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	SEB SA offers only limited insight into its climate-related lobbying. On policy substance, it references broad themes such as planned-obsolescence rules, “Eco-design & Energy labelling” requirements and a French “circular VAT”, but it does not name the bills or regulatory texts involved, making it difficult to pinpoint the exact measures it has tried to influence. The company provides a glimpse of its methods, noting that it supports its positions “by providing public authorities and key opinion leaders (NGOs for example) with position papers” and that it has taken part in a working group run by France’s Direction Générale des Entreprises alongside Ademe and the Commissariat général au développement durable, yet this single example is the only occasion where both the mechanism and the governmental targets are identified. Desired outcomes are set out only in broad terms—such as an “increase of the legal warranty period”, new “regulation on product/component lifespan”, or a general statement that “we support the legislation with no exceptions” on environmental labelling—without quantifiable objectives or detail on how the company wishes the rules to be amended. As a result, the disclosure leaves significant gaps on exactly which climate policies it engages with, how frequently and through which channels it lobbies, and the specific policy changes it seeks.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	SEB SA has established clear structures for CSR oversight, noting that “Implementation of CSR strategy is overseen at Executive Committee level and regular presentations are made on the subject to the Board of Directors” and that it created a “Strategic and CSR Committee to evaluate the Group’s CSR policy and, more specifically, to set targets, measure progress, and ensure that tools for measuring non-financial performance are put in place.” The Group “regularly communicates its opinion about the potential consequences of an action or a decision to the authorities” and “provides insights through professional associations” such as AFEP, FIEEC, GIFAM, SYNETAM, UIMM and APPLiA. SEB SA confirms it has a public commitment or position statement to “conduct your engagement activities in line with the goals of the Paris Agreement.” However, we found no evidence of a dedicated lobbying-governance process, such as a policy outlining how its direct and indirect lobbying is monitored or aligned with its climate objectives, nor any specific individual or committee assigned to oversee lobbying activities.	1