TMBThanachart Bank PCL – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	TMBThanachart Bank PCL demonstrates a strong governance framework for both its direct and indirect climate-related lobbying activities, anchored by a structured alignment process and clear oversight. The Sustainability function “seek[s] engagement opportunities, assess[es] the alignment of our climate position and climate change policy positions of trade associations where we belong, and report[s] on progress of our actions on a regular basis,” while the Chief Commercial Banking Officer is tasked with ensuring “alignment of our climate position and climate programs to support Paris Agreement and Thailand’s commitment” through client advisory and policymaker engagement. The Board of Directors “holds the highest responsibility for approving the Bank’s climate strategy and positions on public policies to ensure alignment” and has placed “climate issues on the agenda for the BoD on a quarterly basis” to reinforce accountability. Oversight is delegated to the Risk Oversight Committee (ROC), which is empowered to “oversee the management of climate-related risks, the practice of responsible lending, and the evaluation of environmental and social risks” and receives “climate-related risk indicators ... quarterly” to guide its review and endorsement of strategic directions and policies. Additionally, the Chief Risk Officer “monitor[s] the progress of our implementation plans and regularly report[s] on climate risk-related issues,” providing further transparency and assurance that the Bank’s lobbying engagement aligns consistently with its climate commitments. View Sources	B

Overall Assessment

Analysis

Score

Strong

TMBThanachart Bank PCL demonstrates a strong governance framework for both its direct and indirect climate-related lobbying activities, anchored by a structured alignment process and clear oversight. The Sustainability function “seek[s] engagement opportunities, assess[es] the alignment of our climate position and climate change policy positions of trade associations where we belong, and report[s] on progress of our actions on a regular basis,” while the Chief Commercial Banking Officer is tasked with ensuring “alignment of our climate position and climate programs to support Paris Agreement and Thailand’s commitment” through client advisory and policymaker engagement. The Board of Directors “holds the highest responsibility for approving the Bank’s climate strategy and positions on public policies to ensure alignment” and has placed “climate issues on the agenda for the BoD on a quarterly basis” to reinforce accountability. Oversight is delegated to the Risk Oversight Committee (ROC), which is empowered to “oversee the management of climate-related risks, the practice of responsible lending, and the evaluation of environmental and social risks” and receives “climate-related risk indicators ... quarterly” to guide its review and endorsement of strategic directions and policies. Additionally, the Chief Risk Officer “monitor[s] the progress of our implementation plans and regularly report[s] on climate risk-related issues,” providing further transparency and assurance that the Bank’s lobbying engagement aligns consistently with its climate commitments.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	TMBThanachart Bank provides only limited transparency around its climate-policy lobbying. The bank notes that it “works with the Bank of Thailand, the Thai Bankers’ Association and other policymakers to raise standards for sustainable financing” and to help develop a national taxonomy, but it does not explain whether these interactions occur through formal consultations, written submissions, meetings or any other identifiable means, nor does it list multiple mechanisms. It references several climate-related policy frameworks—including Thailand’s Alternative Energy Development Plan, the Transportation Development Framework, the National Electric Vehicle Policy Committee, Thailand’s Taxonomy, and external measures such as the EU CBAM and EU ETS—yet it does not confirm that the bank has actively lobbied these instruments or provide detail on the substance of any input. Finally, while the disclosure reiterates broad aims such as supporting Thailand’s net-zero pathway and ending coal project financing by 2028, it offers no concrete legislative or regulatory outcomes the bank is seeking to secure. Overall, the narrative suggests some engagement with policymakers but leaves the specific policies, lobbying methods and desired outcomes largely undefined.	D