Banco Santander SA

Banco Santander SA has developed a robust governance framework to align its climate-related engagement and lobbying activities with its climate change strategy. The bank explains that "Our engagement with trade bodies reflects our policy priorities and is aligned with our strategy," illustrating its approach to ensure indirect lobbying through trade associations does not contradict its commitments. It also notes that in "coordination with the Public Policy team, risk and other relevant areas, [it] provides continuous input ... to the climate change and Environmental, Social & Governance (ESG) regulatory consultations," showing active management of direct policy advocacy. Oversight is assigned to senior governance bodies: the Responsible Banking Forum (RBF) "reviews implementation of the Group's responsible banking agenda and presents its findings to the RBSCC," while the Board Responsible Banking, Sustainability and Culture Committee (RBSCC) "supports the Board of Directors in supervising the Group's responsible banking agenda and strategy" and has reviewed climate change topics at every meeting. The Board Risk Committee (BRC) further "monitors the Risk Appetite Statement every quarter, including climate finance metrics and limits," ensuring regular monitoring and risk alignment. This governance is reinforced by the fact that "the Internal audit function conducted the first review of the climate change project in 2021, proposing new control measures to reinforce governance." We found no evidence that the company publishes a dedicated climate-lobbying alignment report or commissions an external audit of its lobbying practices. Overall, these disclosures demonstrate strong governance of both direct and indirect climate lobbying through defined policies, multiple oversight committees, and recurring review processes, although the absence of a specific public lobbying audit or report limits transparency of climate-lobbying alignment.