TBC Bank Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	TBC Bank Group PLC provides extensive information about its ESG governance structures, including the roles of the Board of Directors, ESG and Ethics Committee, and various management-level committees. For example, the ESG and Ethics Committee is tasked with "periodical review of the Group’s ESG strategy, including climate strategy, as well as implementation plans and monitoring of its execution" and meets "at least four times per year." Additionally, the ESG Coordination Department is described as a "dedicated organizational unit/person within the TBC Bank which/who coordinates the process of the climate action among involved parties." However, while these structures indicate a strong focus on ESG and climate-related governance, there is no explicit mention of processes or mechanisms to ensure that lobbying activities—whether direct or indirect—are aligned with climate commitments or the goals of the Paris Agreement. The evidence does not describe how lobbying activities are monitored, reviewed, or aligned with climate goals, nor does it provide details on actions taken to address misalignment in lobbying positions or trade association memberships. Furthermore, while the company states it has a public commitment to align engagement activities with the Paris Agreement, this does not constitute evidence of a lobbying governance process. Therefore, we found no evidence of a defined governance framework for lobbying activities, particularly in relation to climate lobbying. View Sources	E

Overall Assessment

Analysis

Score

None

TBC Bank Group PLC provides extensive information about its ESG governance structures, including the roles of the Board of Directors, ESG and Ethics Committee, and various management-level committees. For example, the ESG and Ethics Committee is tasked with "periodical review of the Group’s ESG strategy, including climate strategy, as well as implementation plans and monitoring of its execution" and meets "at least four times per year." Additionally, the ESG Coordination Department is described as a "dedicated organizational unit/person within the TBC Bank which/who coordinates the process of the climate action among involved parties." However, while these structures indicate a strong focus on ESG and climate-related governance, there is no explicit mention of processes or mechanisms to ensure that lobbying activities—whether direct or indirect—are aligned with climate commitments or the goals of the Paris Agreement. The evidence does not describe how lobbying activities are monitored, reviewed, or aligned with climate goals, nor does it provide details on actions taken to address misalignment in lobbying positions or trade association memberships. Furthermore, while the company states it has a public commitment to align engagement activities with the Paris Agreement, this does not constitute evidence of a lobbying governance process. Therefore, we found no evidence of a defined governance framework for lobbying activities, particularly in relation to climate lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	TBC Bank Group PLC provides a generally detailed picture of its climate-policy lobbying. It names two distinct regulatory initiatives it has worked on with the National Bank of Georgia – the forthcoming “Sustainable (green and social) Finance Taxonomy” and the “methodology and standard for calculating Scope 3 emissions including financed emissions according to PCAF Methodology for the financial sector in Georgia” – making it clear which policies are being influenced and in which jurisdiction. The company is also explicit about how it has lobbied: it “reviewed the draft of the green and social taxonomy, provided … comments and suggestions,” “conducted several meetings with the National Bank of Georgia,” and engaged in “close collaboration … working together on the elaboration of the methodology/tool,” clearly identifying the regulator as the target of these efforts. Finally, TBC Bank sets out the outcomes it is pursuing, noting that “most of our recommendations were considered” in the taxonomy and that it seeks a Scope-3 methodology that is “sharable and usable for all the financial institutions in Georgia,” while declaring its position as “Support with no exceptions” and confirming alignment with the Paris Agreement. This combination of specific policies, clear mechanisms and targets, and articulated desired results demonstrates a strong level of transparency around the bank’s climate-related lobbying.	B