Danske Bank A/S

Danske Bank outlines a clear governance structure for aligning its policy influencing activities with its climate objectives, stating that "the Executive Leadership Team sets Danske Bank's position and strategy on climate change and our sustainable finance policy," and that those positions are "represented in the Business Integrity Committee," which is its "highest ranking committee for decision-making on sustainability issues." The bank further explains that "sustainability incl. climate change is a key focus of our strategy for Group Communications, which also includes Public Affairs" and that "activities relating to climate change are aligned through ongoing dialogue between our Group Sustainability unit and our Group Public Affairs unit." The inclusion of the "Head of Group Public Affairs" in the "Sustainable Finance Council" is designed "to ensure alignment on this central area in relation to activities that influence public policy." While reporting that each manager must ensure their "Engagement Guidelines are known and complied with" under the bank's "Code of Conduct and Conflict of Interest Policy," these provisions govern engagement with investee companies rather than the bank's own industry memberships. We found no evidence of a structured process to assess or address conflicts within trade or industry associations, nor any publicly available audit or review specifically evaluating how Danske Bank's external policy engagements align with the goals of the Paris Agreement.