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| Overall Assessment |
Comment |
Score |
| Moderate |
National Bank of Canada provides a reasonable level of detail on which climate-related rules it seeks to influence, naming the province’s “Electrification and Climate Change Plan 2030,” the earlier “Montreal Climate Plan 2016-2020,” and a suite of international climate-reporting standards under development by the ISSB, FSB, SEC, OSFI, CSA and BCBS. The Bank also explains how it participates: it submits consolidated comment letters through the Canadian Bankers Association, and it sits on a Quebec government climate-finance advisory committee—disclosing both the collaborative mechanism and the specific regulators and standard-setters targeted. However, it says much less about what it hopes to achieve. Beyond stating that it favours “putting in place harmonized disclosure based on the principles for the effective management and supervision of climate-related financial risks and opportunities to build resilience against climate-related risks and address vulnerabilities,” the Bank offers only broad aspirations to support a low-carbon transition and does not spell out concrete legislative changes it wants. As a result, while the policies engaged and the channels used are described with moderate transparency, the desired outcomes remain largely generic.
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2
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| Overall Assessment |
Comment |
Score |
| Limited |
National Bank of Canada (NBC) demonstrates a structured approach to ESG governance, with multiple committees and teams dedicated to advancing its environmental, social, and governance strategy. The ESG Committee, led by senior executives, oversees the implementation of climate-related commitments, including the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) and the United Nations Principles for Responsible Banking (PRB). The Committee reports twice a year to the Conduct Review and Corporate Governance Committee and interacts with other Board committees on specific topics. NBC also collaborates with external groups, such as the Canadian Bankers Association and the Partnership for Carbon Accounting Financials (PCAF), to align its strategies with the Paris Agreement and improve climate data methodologies. However, while the Bank mentions its involvement in public policy activities and adherence to ethical standards, there is no explicit disclosure of a governance process specifically designed to ensure alignment of lobbying activities—direct or indirect—with its climate commitments. Statements such as "the Bank is committed to being transparent in all its actions and activities with respect to public policy" and "we submit a report on our activities to the registers of lobbyists" focus on compliance and transparency rather than detailing mechanisms for monitoring or managing lobbying alignment. Additionally, while the ESG Committee and other governance structures are robust in addressing broader ESG and climate strategies, there is no evidence of a dedicated process or audit for climate lobbying alignment, nor any mention of actions taken to address misalignment in trade associations or industry bodies. This indicates limited governance specific to lobbying activities.
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1
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