Societe Generale SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Societe Generale SA has demonstrated a high level of transparency in its climate lobbying disclosures. The company clearly identifies multiple climate-related policies and regulatory frameworks by naming specific initiatives such as its involvement with the "EFRAG Standards on CSRD disclosures," participation in consultations on the European Sustainable Reporting Standard and the Net Zero Industry Act, and references to the EU Green Bond Standard among others. In addition, Societe Generale has provided detailed information about its lobbying mechanisms by describing concrete approaches—such as "meetings with policy makers at national or EU level," contributions to consultations and hearings, and the preparation of position papers—to directly influence targeted policy-makers like the European Commission and other regulatory bodies. Furthermore, the company articulates its desired policy outcomes with clarity, including specific targets such as reducing exposure to oil and gas production by 20% by 2025 and achieving a CO2 emission intensity target of 125g CO2 per kWh by 2030, alongside broader objectives aligned with the Paris Agreement and the energy transition. These detailed disclosures underscore Societe Generale's comprehensive approach to communicating its climate lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Strong Societe Generale demonstrates strong governance in its climate lobbying processes, particularly through its integration of climate-related considerations into its governance structure and operational frameworks. The company has established clear oversight mechanisms, such as the Responsible Commitments Committee (CORESP), which "deals with topics related to the Group's commitments and normative framework in CSR (including CSR sector policies), culture and conduct, or other topics that have an impact on the Group's responsibility or reputation." This committee is chaired by the CEO or Deputy CEO sponsoring CSR and met 12 times in 2021 to address issues like "the update of sector policies, such as the oil & gas policy; the alignment of Societe Generale's own operations; and a biodiversity roadmap." Additionally, the Risk Committee (CORISQ) reviews climate-related risks annually, including "the 'reference climate scenario' of the Group and the portion of the credit portfolio exposed to climate-related risks (including alignment indicators)." The governance structure also includes dedicated roles for climate-related oversight, such as the Chief Sustainability Officer, Hacina Py, who "reports directly to General Management" and co-sponsors the 'ESG by Design' program. Furthermore, the Group Management Committee includes several individuals with specific responsibilities for climate-related affairs, such as Diony Lebot, Deputy CEO, who oversees "all ESG policies and their effective incorporation into the strategic trajectories adopted by the Group's business units and functions." Societe Generale has also implemented processes to ensure alignment of its lobbying activities with climate goals. For example, the company uses the Corporate Climate Vulnerability Indicator (CCVI) to assess transition risks on its credit portfolio, identifying clients vulnerable to transition risks and examining their strategies. The CCVI is reviewed annually by the CORISQ, and "attention is paid to the timeliness of the client's strategic shift compared to that of the scenario." Additionally, the company has developed sector-specific Environmental & Social (E&S) policies, which are "approved by the Responsible Commitments Committee 'CORESP'" and aim to manage E&S risks associated with business transactions and clients' activities. While Societe Generale has not published a detailed lobbying audit, its governance processes, including the integration of alignment indicators into the Risk Appetite Framework (RAF) and the monitoring of alignment thresholds, indicate a robust approach to ensuring climate lobbying alignment. The thresholds are "reviewed annually by the Risk Committee 'CORISQ'" and are used to alert when misalignment becomes too serious, requiring corrective action plans from business lines. 3