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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Eurobank provides a highly transparent account of its climate lobbying activities by naming multiple specific policies it has engaged with—such as the Greek Climate Law 4936/2022, the Exoikonomo Programmes for residential energy-efficiency financing, the ECB Guide on climate-related and environmental risks, Commission Implementing Regulation (EU) 2022/2453, the EU Taxonomy, and the Corporate Sustainability Reporting Directive (CSRD). It also details its mechanisms of influence, reporting that it “participated in committees regarding the development & implementation of new Exoikonomo programmes,” took part in the ECB’s supervisory climate risk stress test, and contributed to the drafting of the EBA Guidelines on loan origination and monitoring. Finally, Eurobank clearly defines the outcomes it seeks: it aims to “disclose meaningful and comparable prudential information on environmental, social and governance (ESG) risks,” enhance its practices in line with supervisory milestones, update its risk management procedures to cover additional ESG risk aspects, align its frameworks with the EU Taxonomy, and modernize its reporting under the CSRD. These disclosures collectively demonstrate a comprehensive level of transparency around its climate lobbying engagement.
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4
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| Overall Assessment |
Comment |
Score |
| Limited |
Eurobank Ergasias Services and Holdings SA discloses extensive structures for managing sustainability and climate-related risks, yet almost none of the material addresses how the bank governs its political advocacy or trade-association engagement. The only direct reference found is the statement that the organisation has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” indicating an intention to align any external engagement with climate objectives. However, apart from this high-level pledge, the evidence on sustainability governance focuses on risk management and internal oversight—such as the “Group Sustainability Risk… responsible for overseeing, monitoring, and managing sustainability risks” and the creation of a “Sustainability Management Committee… responsible for climate-related and environmental risks”—without explaining whether or how these bodies review lobbying positions, monitor trade-association affiliations, require approvals for policy advocacy, or report on lobbying alignment. We found no disclosure that names a person or committee specifically charged with overseeing lobbying activities, no description of processes to assess or correct misaligned direct or indirect lobbying, and no published review or audit of the bank’s policy advocacy. Therefore, the disclosure shows only a limited, principle-level commitment and provides no evidence of a structured governance process for lobbying alignment.
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1
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