Lloyds Banking Group PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Lloyds Banking Group discloses its climate-policy lobbying in a highly granular way. It names multiple specific measures it has engaged on, including the UK Department for Transport’s “Policy design features for the car and van zero emission vehicle (ZEV) mandate”, the wider Green Paper on a New Road Vehicle CO2 Emissions Regulatory Framework, proposed reforms to “Stamp Duty Land Tax (SDLT) to incentivise energy-efficiency improvement works”, and a call for “clarity on medium-term benefit in kind rates post 2025” to accelerate electric-vehicle uptake. The company also explains exactly how and with whom it engages, referencing bilateral and multilateral calls with BEIS officials, meetings with the Minister for Business, Energy and Corporate Responsibility, written submissions to the Department for Transport, direct discussions with “HMT officials”, the “Exchequer Secretary”, “No10 officials”, Welsh Government representatives, and attendance at Westminster events where it met MPs as well as Treasury and Department for Transport representatives. It is equally explicit about the policy changes it seeks: support for “higher trajectory targets for vans”, inclusion of long-range PHEVs, grid decarbonisation targets linked to EV growth, opposition to certificate banking or pooling in the ZEV scheme, SDLT relief to spur home energy-efficiency retrofits, and the above-mentioned benefit-in-kind certainty for EVs. By detailing the policies addressed, the exact engagement channels, the government targets and the concrete outcomes it is pursuing, the group demonstrates a comprehensive level of transparency over its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Lloyds Banking Group discloses a structured process to oversee and align its climate-related lobbying, stating that its “climate change strategy is communicated and controlled via Group governance, specifically our Group Net Zero Committee (GNZC), with escalation into Responsible Business Committee (RBC) as required,” which indicates that a formal board-level body reviews policy engagement. The company explains that “GPA also work with the business to coordinate our engagement strategy… with direct representation from business areas involved in engagements,” showing day-to-day management of direct lobbying, while indirect lobbying through trade bodies is addressed because “where we are members of other organisations… that request is reviewed at Director level of the relevant business areas with approval obtained by the level of signatory required, e.g. Group Director or CEO.” In addition, “public policy campaign activity is tracked through GNZC with regular deep dives on engagement activity across specific sectors,” providing evidence of ongoing monitoring, and the firm has a “public commitment… to conduct [its] engagement activities in line with the goals of the Paris Agreement.” Together these disclosures demonstrate strong governance features—clear oversight bodies, defined review and approval procedures, and coverage of both direct and association-based lobbying—although the company does not disclose a standalone lobbying-alignment report or an external audit of trade-association positions, so transparency remains less comprehensive than best practice.	3