Danske Bank A/S

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Danske Bank A/S provides a high level of detail about its climate-policy lobbying. It names multiple identifiable measures it seeks to influence, including the EU Commission’s Sustainable Finance Action Plan and the “EU regulation on sustainable finance following from the EU Commission's Sustainable Finance Action Plan,” the EU Taxonomy Regulation (where it aims to “contribute to the further development of the EU taxonomies”), and the EU Commission’s work on eco-labels for financial products through participation in the Commission’s ad-hoc working group. The bank also explains clearly how it carries out this engagement. It lists direct tools such as “letters, e-mails, and meetings (in person or virtually) with the relevant representatives” and discloses indirect channels through “engagements conducted by a third-party on behalf of Danske Bank” and participation in trade associations such as Finance Denmark and UNEP-FI. Named targets include “government officials,” “Members of Cabinet,” the “EU Commission,” the “Central Bank,” and other state representatives, and the bank notes that it “applied to become a member of the EU Commission’s platform on Sustainable Finance” and “participates in the EU Commission’s ad-hoc working group on eco-labelling.” Regarding the outcomes it seeks, the bank sets out several concrete positions: it “supports the development of a taxonomy on significantly harmful economic activities,” “backs the introduction of an ‘intermediate transition’ label,” and aims to see the Sustainable Finance Action Plan implemented in a way that is “coherent across legislative acts” and accommodates “Danish/Nordic specificities such as the Danish Mortgage System.” It also states that it “voted in favor of proposals urging companies to align their lobbying activities with the climate targets of the Paris Agreement.” While these statements articulate clear objectives, they are fewer in number and less granular than the disclosures on policies and mechanisms. Overall, the company demonstrates strong transparency on the climate-related policies it engages on and the mechanisms and targets of that engagement, and it provides a reasonably clear, though somewhat less detailed, description of the specific outcomes it seeks.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	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.	2