Commonwealth Bank of Australia

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Commonwealth Bank of Australia provides extensive, specific detail about its climate-policy lobbying. It lists multiple named measures it has engaged on, including the Clean Energy Regulator’s Corporate Emissions Reductions Transparency (CERT) report pilot, the Australian Prudential Regulation Authority’s Climate Vulnerability Assessment for Authorised Deposit-taking Institutions, support for the National Greenhouse and Energy Reporting scheme, Treasury consultations on “mandatory climate-related financial disclosures”, the Government’s emerging Sustainable Finance Strategy and taxonomy, as well as energy-transition programs such as the Powering the Regions Fund, the Capacity Investment Scheme and Rewiring the Nation. The bank also spells out how it seeks to influence these measures. It describes direct participation in the CERT pilot and the CVA, direct dialogue with the Net Zero Economy Agency and other government departments, and indirect advocacy “through the Australian Banking Association, the Business Council of Australia, ASFI and the Climate Measurement Standards Initiative”, thereby naming both the mechanisms (consultations, pilots, industry working groups, research partnerships) and the targets (APRA, Treasury, Clean Energy Regulator, Net Zero Economy Agency). Finally, CBA is explicit about the outcomes it pursues: it advocates for “mandatory carbon reporting” with a clear implementation roadmap, the development of “sectoral decarbonisation pathways”, the introduction of a sustainable finance taxonomy, and policies that deliver an inclusive transition such as affordable-housing measures and insurance reforms to protect customers from climate risks. These disclosures demonstrate a high level of transparency around the bank’s climate-related lobbying activities, covering the policies addressed, the channels used and the concrete results it is seeking to achieve.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Commonwealth Bank of Australia integrates its climate objectives into its overarching Environmental and Social (E&S) governance structures but does not articulate a distinct lobbying governance process dedicated to climate policy advocacy. Specifically, the Bank requires that “all direct and indirect activities that influence policy are expected to be consistent with the Group overall climate change and ESG related strategy,” and has established a “Group-wide Environmental and Social Policy [that] sets a foundation and creates a framework for understanding and managing the Group’s direct and indirect activities that could influence policy,” with “public disclosure of the Group’s Environmental and Social Framework” and “the development of climate change training” to support alignment. Oversight is provided at the highest level, with the Board “oversees adherence to the Group’s Environmental and Social (E&S) Policy” and an “ELT E&S Committee [that] is chaired by the Group Chief Executive Officer (CEO) and meets monthly. It directs and oversees the Group’s implementation of the E&S strategy, governance, priorities for implementation and disclosures.” For indirect lobbying, the Bank commits to “establish an annual review process to understand alignment between our position on climate and that of the industry associations in which we are active participants” and, if misalignments are identified, to “proactively share our position and rationale with the industry association.” However, the company does not disclose a tailored procedure for reviewing or approving specific lobbying positions, nor does it designate a dedicated individual or team solely responsible for governing climate-related lobbying activities.	2