Bank of Montreal

Bank of Montreal has implemented processes to govern its climate-related engagement, but it does not disclose a fully comprehensive lobbying alignment framework. For example, the bank explains that "Only authorized BMO representatives knowledgeable of climate strategy are involved in climate related engagement with stakeholders or policy makers," and notes that "BMO's Sustainability Council...are kept apprised of climate strategy matters through quarterly Sustainability Council meetings, including any engagement opportunities," which demonstrates a defined mechanism to ensure direct lobbying aligns with its climate objectives. It is also stated that "Our Government Relations team manages lobbying activity and tracks our engagement with public officials," suggesting procedural oversight of its general policy advocacy. However, we found no evidence of how indirect lobbying - such as through trade or industry associations - is monitored for climate alignment, nor does the bank disclose a board-level sign-off process, a dedicated climate-lobbying review or audit, or specific criteria for evaluating the consistency of all lobbying activities with its climate strategy. While roles like the General Counsel and sustainability committees are clearly defined within its broader sustainability governance, their connection to managing and aligning lobbying efforts on climate issues is not explicitly disclosed, indicating moderate but incomplete oversight of climate lobbying.