Sumitomo Mitsui Financial Group Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Sumitomo Mitsui Financial Group discloses only rudimentary oversight of climate-related advocacy. It notes that "the progress/status of our engagement activities are reported to the management periodically" and that management "receive reviews upon the alignment of our engagements to our climate related strategies," showing that some form of review exists to keep external engagement consistent with the company’s climate strategy. Oversight appears to sit with senior sustainability bodies, as "the Playbook has been reviewed by SMBC Group's Sustainability Committee, an internal board committee, and approved by the Group's Chief Sustainability Officer (CSuO), who is responsible for planning and managing sustainability-related initiatives," but the description stops short of explaining how lobbying activities are monitored day-to-day, how misalignment is identified, or what actions follow any breach. Although the group affirms it has "a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement," we found no evidence of a structured process that covers indirect lobbying via trade associations, no disclosure of a lobbying-alignment audit, and no named individual or committee explicitly charged with reviewing the substance of policy advocacy. As a result, the company’s publicly available information indicates only limited governance of lobbying and climate advocacy rather than a comprehensive or transparent framework. View Sources	D

Overall Assessment

Analysis

Score

Limited

Sumitomo Mitsui Financial Group discloses only rudimentary oversight of climate-related advocacy. It notes that "the progress/status of our engagement activities are reported to the management periodically" and that management "receive reviews upon the alignment of our engagements to our climate related strategies," showing that some form of review exists to keep external engagement consistent with the company’s climate strategy. Oversight appears to sit with senior sustainability bodies, as "the Playbook has been reviewed by SMBC Group's Sustainability Committee, an internal board committee, and approved by the Group's Chief Sustainability Officer (CSuO), who is responsible for planning and managing sustainability-related initiatives," but the description stops short of explaining how lobbying activities are monitored day-to-day, how misalignment is identified, or what actions follow any breach. Although the group affirms it has "a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement," we found no evidence of a structured process that covers indirect lobbying via trade associations, no disclosure of a lobbying-alignment audit, and no named individual or committee explicitly charged with reviewing the substance of policy advocacy. As a result, the company’s publicly available information indicates only limited governance of lobbying and climate advocacy rather than a comprehensive or transparent framework.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Sumitomo Mitsui Financial Group demonstrates a high degree of transparency around the climate-related policies on which it engages. It clearly names its discussions with the Financial Services Agency on the “climate-related financial guidelines” and its provision of feedback to the Basel Committee on Banking Supervision and the Network for Greening the Financial System on their “regulations/policies under consideration,” offering identifiable mechanisms—direct discussions and collaborative feedback—and explicit targets. However, while SMFG states that it supports these guidelines “with no exceptions,” it does not articulate any specific amendments, measurable targets, or detailed policy outcomes it is seeking through its lobbying efforts.	B