Itau Unibanco Holding SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Itaú Unibanco has been transparent in disclosing how it engages with policymakers and the outcomes it seeks, although its policy disclosures are centered primarily on Brazil’s carbon market. The bank identifies its lobbying focus on the regulated and voluntary carbon pricing framework, including draft legislation for a cap-and-trade system. It describes concrete engagement mechanisms—active participation in “consultations and public events by the Brazilian government, specially about a Brazilian cap and trade system,” direct dialogue with the Executive, Legislative, and Judiciary branches, and collaboration through trade bodies such as the Brazilian Federation of Banks and CEBDS, which “delivered to the Brazilian vice president, with the support of Itaú and other Brazilian companies, a position with recommendations for the implementation of a regulated carbon market in the country.” Finally, Itaú is explicit about the policy outcomes it supports: “the development of a cap and trade market that encourages the decarbonization of Brazilian industry in line with its work on sectoral decarbonization targets in the portfolio,” alongside advocating incentives for low-carbon technologies and renewable energy sources.	3

Lobbying Governance

Overall Assessment	Comment	Score
None	Itaú Unibanco details extensive governance for climate risk and ESG strategy, describing that “legislative proposals are monitored, analyzed and, based on the probability of approval and on the analysis of financial and image risks, performance strategies are developed within the scope of the legislative process,” and noting that “the principles set forth by our Code of Ethics and our Government Relations Policy guide the permitted and expected conduct of our employees in cases of relations with public agents.” However, the company does not disclose any mechanisms specifically to ensure its lobbying activities are aligned with its climate-change goals, no policy requiring review or sign-off of direct or indirect lobbying positions against its climate strategy, no named individual or formal body that oversees lobbying alignment, and we found no evidence of processes to evaluate or adjust participation in industry associations based on climate compatibility.	0