Grupo Financiero Banorte SAB de CV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Grupo Financiero Banorte SAB de CV has documented a formal mechanism to vet its climate-related advocacy, indicating that “the process we follow includes: the review of initiatives according to their importance and contribution to our sustainability and climate strategies; the evaluation of needs in terms of resources, time, collaborators, budget; and the presentation of the initiatives to our executive management and, if necessary, the senior management for validation.” It also affirms that “we regularly participate in Sustainability Committees, working groups and projects focused on climate change through the Bank of Mexico […] the Mexico Banks Association […] the Green Financial Advisory Council (CCFV),” showing an alignment of indirect lobbying through industry bodies. Oversight is performed by executive and senior management and embedded in broader “governance bodies” like the Sustainability Committee, which “has the authority to approve the climate strategy and validate action plans for its execution.” However, we found no evidence of a dedicated review process or governance structure for direct lobbying activities, no publicly available audit or report on lobbying alignment, and no explicit criteria for disengaging from associations whose positions may conflict with Banorte’s climate objectives, indicating that its lobbying governance remains moderate and less transparent in scope. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Grupo Financiero Banorte SAB de CV has documented a formal mechanism to vet its climate-related advocacy, indicating that “the process we follow includes: the review of initiatives according to their importance and contribution to our sustainability and climate strategies; the evaluation of needs in terms of resources, time, collaborators, budget; and the presentation of the initiatives to our executive management and, if necessary, the senior management for validation.” It also affirms that “we regularly participate in Sustainability Committees, working groups and projects focused on climate change through the Bank of Mexico […] the Mexico Banks Association […] the Green Financial Advisory Council (CCFV),” showing an alignment of indirect lobbying through industry bodies. Oversight is performed by executive and senior management and embedded in broader “governance bodies” like the Sustainability Committee, which “has the authority to approve the climate strategy and validate action plans for its execution.” However, we found no evidence of a dedicated review process or governance structure for direct lobbying activities, no publicly available audit or report on lobbying alignment, and no explicit criteria for disengaging from associations whose positions may conflict with Banorte’s climate objectives, indicating that its lobbying governance remains moderate and less transparent in scope.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Grupo Financiero Banorte offers only limited insight into its climate-related lobbying. It indicates that it participates in sector forums and associations—such as "the Global Leaders for Climate Action forum" at COP26, the Net-Zero Banking Alliance, the Mexican Banking Association (ABM) and its co-chair role in the Green Finance Advisory Council (CCFV)—but it does not name any specific pieces of legislation or regulations it has tried to influence; the references to developing “a Sustainable Taxonomy for the Mexican banking industry” and aligning with the Paris Agreement remain high-level themes rather than identifiable bills or rules. The company describes its approach mainly as participation in industry bodies and alliances, noting a "role in promoting updates to laws and regulations," yet it does not clarify what concrete mechanisms (letters, consultations, direct meetings) were used nor which government agencies or officials were targeted. Finally, the outcomes it seeks are framed in broad terms—"accelerating actions to mitigate and adapt to climate change," "promoting a sustainable recovery," and encouraging disclosure standards—without setting out measurable policy changes or positions it is advocating. This leaves stakeholders with only a general sense that the bank supports sustainable finance, rather than a clear picture of how, where, and to what end it lobbies on climate policy.	D