Emirates NBD Bank PJSC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Emirates NBD provides only limited insight into its climate-related lobbying. The bank references broad frameworks such as the UAE Net Zero 2050 strategy, the EU and UK Emissions Trading Schemes and its participation in COP28, but these references are framed as alignment with existing initiatives rather than evidence that it has actually tried to influence any particular law or regulation. Its only indication of engagement is a general statement that it is “working with the UAE Government and various other partners to drive meaningful conversation and action,” which names a policymaking target but gives no detail on how the bank engages—there is no description of letters, meetings, coalition work, or consultation submissions. Likewise, the disclosures contain no explanation of the specific policy outcomes the bank supports or opposes; they simply express a general commitment to sustainability and carbon-market facilitation. As a result, the company’s transparency on climate lobbying mechanisms, the policies it seeks to influence, and the outcomes it pursues remains minimal.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Emirates NBD Bank PJSC articulates a broad sustainability governance structure but provides no specific governance for its lobbying activities. For instance, it affirms it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and describes “engaging our external stakeholders through our materiality assessment using GRI and SASB” to shape its climate strategy. While the Board of Directors (BOD) and the Board Nomination, Remuneration and ESG Committee “review[] progress every quarter” on ESG initiatives, the company does not disclose any processes for aligning either its direct policy advocacy or its trade association engagement with its climate commitments, nor does it identify an individual or a formal body tasked with overseeing or approving lobbying positions. We found no evidence of lobbying position sign-offs, association reviews, or dedicated audits of climate-related lobbying, indicating limited governance over its climate lobbying efforts.	1