Banco do Brasil SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Banco do Brasil discloses a high level of detail about its climate-policy lobbying. It names a range of specific measures it has worked on, including Central Bank of Brazil Public Consultations 82, 85 and 86 and the resulting CMN Resolutions 4,943 and 4,945 and BCB Resolution 139 on social, environmental and climate-risk management, as well as multiple bills before Congress such as Environmental Licensing (Bill 3729/2004, Senate Bill 168/2018, Bill 2159/2021) and the Carbon Market and Green Debentures package (Bills 2122/2021, 4028/2021, 4516/2021 and 4464/2021). The company also describes the channels it uses and who it targets: it engages directly with parliamentarians in the National Congress, “acts to suggest enhancements to congressman, directly or through associations like Febraban,” submits formal responses to public consultations, coordinates a dedicated working group and maintains dialogue with the Ministry of Finance, the Secretary of Government of the Presidency, the Central Bank, and industry bodies such as Febraban and the CNF. On objectives, Banco do Brasil explains that it seeks new rules that “enhance the monitoring and tracking of social, environmental and climate risks,” calling for mandatory disclosure requirements and the implementation of its Social, Environmental and Climatic Responsibility Policy (PRSAC), and emphasises that it aims to ensure “the proposals presented are in the best possible shape to meet the aspirations of society as a whole.” While the company is less granular about every individual legislative amendment it supports, the combination of clearly identified policies, mechanisms and stated policy outcomes demonstrates strong transparency around its climate-related lobbying activities.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Banco do Brasil discloses only a high-level commitment to align its external engagement with climate objectives, stating that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement" and that "our planning factors in climate change issues" while highlighting initiatives such as bringing leaders together at the "Global Carbon Market Congress – Decarbonization & Green Investments". These statements indicate intent but the company provides no information about who oversees lobbying, how direct or indirect advocacy is monitored, or what processes are in place to ensure alignment, so the disclosure stops short of describing a structured governance framework for climate-related lobbying.	1