Spar Nord Bank A/S – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Spar Nord Bank A/S has established a robust governance framework for its sustainability and climate-related objectives; however, it does not disclose any specific governance process for lobbying activities. The bank explains that “ESG is a shared responsibility at Spar Nord,” anchored in senior management and overseen by an “ESG steering group” that meets quarterly to discuss “the status of initiatives and relevant areas for attention.” It further clarifies that “Spar Nord’s climate ambition and transition plan for climate change have been approved by the bank’s Board of Directors,” and notes that the Executive Board and specialized committees such as the “Responsible Investment Committee” and “Sustainable Financing Committee” oversee and recommend actions to meet climate targets. While these structures demonstrate clear accountability for climate strategy, we found no evidence of how the bank governs or aligns its direct or indirect lobbying activities with its climate or policy positions, nor any mention of an oversight mechanism, named individual, formal body, or process for reviewing or managing lobbying efforts or engagement with trade associations. View Sources	E

Overall Assessment

Analysis

Score

None

Spar Nord Bank A/S has established a robust governance framework for its sustainability and climate-related objectives; however, it does not disclose any specific governance process for lobbying activities. The bank explains that “ESG is a shared responsibility at Spar Nord,” anchored in senior management and overseen by an “ESG steering group” that meets quarterly to discuss “the status of initiatives and relevant areas for attention.” It further clarifies that “Spar Nord’s climate ambition and transition plan for climate change have been approved by the bank’s Board of Directors,” and notes that the Executive Board and specialized committees such as the “Responsible Investment Committee” and “Sustainable Financing Committee” oversee and recommend actions to meet climate targets. While these structures demonstrate clear accountability for climate strategy, we found no evidence of how the bank governs or aligns its direct or indirect lobbying activities with its climate or policy positions, nor any mention of an oversight mechanism, named individual, formal body, or process for reviewing or managing lobbying efforts or engagement with trade associations.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E