UBS Group AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	UBS Group AG provides a highly detailed picture of its climate-policy lobbying. It names multiple concrete measures it has sought to influence, including the revision of the Swiss CO2-Act, the Swiss Climate and Innovation Act, the development of the “Swiss Climate Scores”, FINMA Circular 2016/01 “Disclosure – banks”, EU initiatives such as the Corporate Sustainability Reporting Directive and the Deforestation Regulation, and the UK Financial Conduct Authority’s Sustainability Disclosure Requirements. The company is equally explicit about how and where it lobbies: it “directly engaged with members of parliament in support of the draft law”, filed a “Consultation response on Swiss ordinance on mandatory climate disclosures for large companies”, participated in public consultations run by FINMA and U.S. prudential regulators, chaired the Institute of International Finance Sustainable Finance Working Group, and channels additional advocacy through trade bodies such as the Swiss Bankers Association and economiesuisse. UBS also clarifies the outcomes it is pursuing: it backed “the new law on climate protection which includes a net-zero target for all Swiss companies and interim reduction targets for different economic sectors”, pressed for higher carbon pricing and other instruments in the revised CO2-Act to “achieve Switzerland’s interim climate goals”, promoted the Swiss Climate Scores to “foster investment decisions that contribute to reaching the climate goals”, and “pitched the idea of a centralized register… containing emission data for buildings” to guide renovation decisions. By naming the specific policies, describing the mechanisms and targets of engagement, and stating the precise legislative or regulatory changes it wants, UBS demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	UBS Group AG provides defined oversight for its lobbying activities, albeit without a dedicated climate-lobbying alignment process. For direct lobbying, it states that "In the US, our lobbying priorities are presented to and approved by the Region Americas’ top management group at the beginning of each year," while governance is vested in a specific role, as "the North America Operating Unit Vice President of Public Policy, Federal Government Relations & Political Engagement is responsible for management of our public policy agenda and political engagement." The company further notes that "UBS engagement policies and processes are reviewed on an ongoing basis, enhanced, monitored, and adapted when insufficient progress is identified, and also in order to incorporate additional PAI indicators and to ensure the key environmental, socials and governance topics are taken into consideration," which signals an established review mechanism. Nevertheless, there is no disclosure of how indirect lobbying is aligned with UBS’s climate objectives—no evidence of association review, exit or alignment procedures—nor is there a published audit or detailed report on climate-related lobbying. Consequently, UBS demonstrates moderate governance of its lobbying in general, with strong direct oversight but limited transparency around climate-focused and trade association lobbying alignment.	2