Raiffeisen Bank International AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Raiffeisen Bank International AG provides limited but tangible insight into how it governs the climate-related positions it takes in policy debates. The company explains that “Commitment or position statements are discussed in an agile modus eg including Strategy, RBI Group ESG & Sustainability Management, Sustainable Finance as well as with Legal department and PR,” indicating that multiple internal functions collectively review and sign off any external engagement to make sure it is consistent with the bank’s climate strategy. This cross-departmental review constitutes a defined mechanism for aligning advocacy with internal policy, and the explicit reference to ESG & Sustainability Management and Legal departments shows that oversight goes beyond the teams that actually conduct lobbying. In practice, the bank applied this process when it decided to “set a sign against the inclusion of nuclear power into the Green EU Taxonomy,” demonstrating that policy stances are vetted for consistency with its “group-wide Code of Conduct and the approach to act as a Responsible Banker.” However, the disclosure does not specify a formal committee or individual at executive or board level with ultimate responsibility, nor does it describe how ongoing monitoring of direct and indirect lobbying is carried out, whether trade-association positions are assessed, or whether misalignments trigger corrective action. The absence of a publicly available lobbying-alignment report or a structured audit further limits transparency. Overall, the evidence suggests a moderate governance approach built around an internal multi-function review of climate-related advocacy, but key details on oversight authority, monitoring frequency, and trade-association governance are not disclosed. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Raiffeisen Bank International AG provides limited but tangible insight into how it governs the climate-related positions it takes in policy debates. The company explains that “Commitment or position statements are discussed in an agile modus eg including Strategy, RBI Group ESG & Sustainability Management, Sustainable Finance as well as with Legal department and PR,” indicating that multiple internal functions collectively review and sign off any external engagement to make sure it is consistent with the bank’s climate strategy. This cross-departmental review constitutes a defined mechanism for aligning advocacy with internal policy, and the explicit reference to ESG & Sustainability Management and Legal departments shows that oversight goes beyond the teams that actually conduct lobbying. In practice, the bank applied this process when it decided to “set a sign against the inclusion of nuclear power into the Green EU Taxonomy,” demonstrating that policy stances are vetted for consistency with its “group-wide Code of Conduct and the approach to act as a Responsible Banker.” However, the disclosure does not specify a formal committee or individual at executive or board level with ultimate responsibility, nor does it describe how ongoing monitoring of direct and indirect lobbying is carried out, whether trade-association positions are assessed, or whether misalignments trigger corrective action. The absence of a publicly available lobbying-alignment report or a structured audit further limits transparency. Overall, the evidence suggests a moderate governance approach built around an internal multi-function review of climate-related advocacy, but key details on oversight authority, monitoring frequency, and trade-association governance are not disclosed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Raiffeisen Bank International AG provides comprehensive and detailed disclosures of its climate-related lobbying activities. It clearly identifies the specific policies it has engaged with, naming multiple European regulations including the “EU taxonomy for sustainable activities,” the “Corporate Sustainability Reporting Directive including EFRAG Standard Setting,” the “Corporate Sustainability Due Diligence Directive,” “EBA ITS on ESG Risks,” the “ECB Guide on Climate related risks,” “SFRD and MIFID II,” and the “Social taxonomy report.” The bank outlines its lobbying mechanisms with high transparency, noting its participation in “official consultation processes of proposed ESG regulations,” the drafting of “position papers,” and organizing “exchange of views with MEPs of the European Parliament, the European Commission or representatives of the Council,” as well as its engagement with national “ministries and regulators,” “supervisory authorities (ECB and other national banks),” and through memberships in the “Sustainable Finance Working Group” of the EACB and think tanks such as “Bruegel or CEPS.” It also articulates the outcomes it seeks, from influencing regulatory developments across the Green Taxonomy, the Corporate Sustainability Reporting Directive, the Corporate Sustainability Due Diligence Directive, and other ESG frameworks, to its explicit opposition to “the inclusion of nuclear power into the green EU Taxonomy,” arguing that nuclear energy is “too dangerous, too expensive, and too sluggishly deployable” and collaborating with stakeholders like the Ludwig Boltzmann Institute for Human Rights to ensure proper policy implementation. This level of detail demonstrates a comprehensive level of transparency around its climate policy lobbying.	A