Standard Chartered PLC

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited Standard Chartered provides only limited insight into its climate-policy lobbying. It does name two identifiable policy processes it has engaged with—the "Sustainable Finance Taxonomy" being developed for Hong Kong SAR and the International Sustainability Standards Board’s draft climate-disclosure standards—demonstrating some openness about the issues on which it comments. For the ISSB work it discloses one concrete mechanism, stating that it supplied "responses to formal consultations" directly to the ISSB, which is a clear, specific channel and target, but no other methods or audiences are described for any of its climate engagements. The bank’s policy positions are also sparsely detailed: in its ISSB submission it "support[s] with minor exceptions" and asks the Board to "consider additional phase in and flexibility for emerging markets," while it records "support with no exceptions" for the Hong Kong taxonomy. Beyond these isolated statements it offers no explanation of further legislative changes, amendments or objectives it is pursuing, nor does it outline other forums, meetings or correspondence. As a result, the disclosures shed some light on which policies the bank comments on and one desired modification, but they leave most of its lobbying mechanisms and sought-for outcomes unexplained. 1
Lobbying Governance
Overall Assessment Comment Score
Strong Standard Chartered PLC articulates a clear governance process for aligning its lobbying activities with its climate commitments, anchored by its Sustainable Finance Regulatory Policy Forum, “appointed by the Group Responsibility and Reputational Risk Committee (GRRRC)”, which “manages the Bank’s positions, external engagement and platform participation with regards to such policy and regulatory developments” and “acts as a clearing house for agreeing, maintaining and updating Bank-wide positions on policy and regulatory developments, ensuring that the Bank is consistent in its external messaging and internal application as well as maximising the Bank’s influence in its engagement with policymakers and regulators”. The bank explicitly aligns all engagement “in line with the objectives of reaching the goals of the Paris Agreement”, covering direct engagement with policymakers and indirect engagement “through trade associations and industry platforms”. Oversight is embedded in the GRRRC, with the Forum required to keep the committee “sighted on horizon policy and regulatory developments” and to “propose recommendations to form implementation programmes”. This demonstrates strong governance across both direct and indirect lobbying channels, but the company does not disclose a dedicated climate-lobbying audit or third-party review, nor a specific cycle of regular reviews beyond its Annual Report and sustainability publications, suggesting an opportunity to enhance transparency and formalize ongoing evaluation. 3