Commonwealth Bank of Australia

Commonwealth Bank of Australia integrates its climate objectives into its overarching Environmental and Social (E&S) governance structures but does not articulate a distinct lobbying governance process dedicated to climate policy advocacy. Specifically, the Bank requires that "all direct and indirect activities that influence policy are expected to be consistent with the Group overall climate change and ESG related strategy," and has established a "Group-wide Environmental and Social Policy [that] sets a foundation and creates a framework for understanding and managing the Group's direct and indirect activities that could influence policy," with "public disclosure of the Group's Environmental and Social Framework" and "the development of climate change training" to support alignment. Oversight is provided at the highest level, with the Board "oversees adherence to the Group's Environmental and Social (E&S) Policy" and an "ELT E&S Committee [that] is chaired by the Group Chief Executive Officer (CEO) and meets monthly. It directs and oversees the Group's implementation of the E&S strategy, governance, priorities for implementation and disclosures." For indirect lobbying, the Bank commits to "establish an annual review process to understand alignment between our position on climate and that of the industry associations in which we are active participants" and, if misalignments are identified, to "proactively share our position and rationale with the industry association." However, the company does not disclose a tailored procedure for reviewing or approving specific lobbying positions, nor does it designate a dedicated individual or team solely responsible for governing climate-related lobbying activities.