National Australia Bank Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive National Australia Bank Limited (NAB) has demonstrated comprehensive transparency in its climate lobbying activities. The company has disclosed specific climate policies it has engaged with, including consultations with the Department of Agriculture, Fisheries and Forestry on the Agricultural and Land Sectoral Plan, the Department of Treasury on Australia's Sustainable Finance Strategy and Climate-related Financial Disclosure Exposure Draft Legislation, and the Australian Sustainability Reporting Standards Boards on the Disclosure of Climate-related Financial Information. Additionally, NAB has engaged with the Department of Climate Change, Energy, Environment and Water on the National Adaptation Plan Issues Paper and the Climate Change Authority's 2024 Issues Paper on Targets, Pathways, and Progress. These references clearly identify the policies and legislative areas NAB has lobbied, ensuring transparency in its climate-related lobbying activities. NAB has also disclosed both direct and indirect lobbying mechanisms, including direct consultations with government entities, participation in industry roundtables, and contributions to industry association submissions and statements. Specific targets include the Department of Agriculture, Fisheries and Forestry, the Department of Treasury, the Australian Sustainability Reporting Standards Boards, the Department of Climate Change, Energy, Environment and Water, and the Climate Change Authority. These disclosures provide clarity on both the methods of engagement and the entities targeted. Furthermore, NAB has been transparent about the specific outcomes it seeks through its lobbying efforts, advocating for sectoral pathways, sustainable finance, emissions reduction, energy efficiency and electrification, climate disclosure and consistent reporting regimes, managing climate risk, just transition for workers and communities, natural disasters, climate resilience, and biodiversity. These clearly stated goals reflect NAB's desired policy changes and outcomes, demonstrating alignment with its climate-related objectives. 4
Lobbying Governance
Overall Assessment Comment Score
Comprehensive NAB's climate lobbying governance is characterized by a comprehensive and detailed framework that clearly demonstrates its commitment to aligning both direct and indirect lobbying activities with its climate goals. Notably, NAB has published its "2024 Climate Report," which outlines its climate‐related lobbying activities and alignment measures, and it specifies that its Chief Climate Officer "oversees and aligns NAB's strategic response" by working closely with key Group Executives, with the Board also receiving regular reports on climate-related matters. This detailed oversight is further supported by internal consultative processes, clear policies for reviewing the advocacy of industry associations, and external assurance by providers such as Ernst & Young, thereby establishing robust monitoring, accountability, and structured governance. Although some documents did not reference governance details, the comprehensive disclosure in the 2024 report and accompanying processes provide clear evidence of strong governance practices for climate lobbying at NAB. 4