Skandinaviska Enskilda Banken AB – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	SEB discloses several elements that indicate a structured, but still partial, governance framework for ensuring that its advocacy and engagement are consistent with its climate objectives. The bank states that “Engagement is coordinated by Sustainable Banking function which reports to CEO and Board that approves strategy,” and the Chief Sustainability Officer sits on the Group Executive Sustainability Committee, signalling that climate-related engagement is embedded in a formal governance chain that reaches the Board. Oversight is further underlined by the statement that “The Board also approves the Corporate Sustainability Policy for the SEB Group… and the thematic policies (on Climate Change…)”, while policies are “annually reviewed by the Bank,” showing a recurring review mechanism. SEB also refers to behavioural expectations by noting “SEB has strict guidelines for unethical influence, whether within business or society,” and that it “does not support political parties through donations,” suggesting internal rules covering political influence. In 2023 it created a dedicated “Public Affairs function” to engage “public decisionmakers and societal stakeholders,” implying a structured channel for direct lobbying. However, the company provides only limited insight into how it actively checks that its lobbying – or that of any trade associations – aligns with its climate strategy; apart from a general expectation that “companies’ public and non-public policy positions do reflect” Paris-aligned transition plans, we found no disclosure of systematic reviews, audits, or decisions to correct or exit misaligned associations. Nor does SEB publish a standalone lobbying-alignment report or detail criteria for assessing individual lobbying activities. This combination of Board-level oversight and stated processes, but absence of deeper monitoring detail or evidence of active alignment work, indicates moderate governance of climate-related lobbying. View Sources	C

Overall Assessment

Analysis

Score

Moderate

SEB discloses several elements that indicate a structured, but still partial, governance framework for ensuring that its advocacy and engagement are consistent with its climate objectives. The bank states that “Engagement is coordinated by Sustainable Banking function which reports to CEO and Board that approves strategy,” and the Chief Sustainability Officer sits on the Group Executive Sustainability Committee, signalling that climate-related engagement is embedded in a formal governance chain that reaches the Board. Oversight is further underlined by the statement that “The Board also approves the Corporate Sustainability Policy for the SEB Group… and the thematic policies (on Climate Change…)”, while policies are “annually reviewed by the Bank,” showing a recurring review mechanism. SEB also refers to behavioural expectations by noting “SEB has strict guidelines for unethical influence, whether within business or society,” and that it “does not support political parties through donations,” suggesting internal rules covering political influence. In 2023 it created a dedicated “Public Affairs function” to engage “public decisionmakers and societal stakeholders,” implying a structured channel for direct lobbying. However, the company provides only limited insight into how it actively checks that its lobbying – or that of any trade associations – aligns with its climate strategy; apart from a general expectation that “companies’ public and non-public policy positions do reflect” Paris-aligned transition plans, we found no disclosure of systematic reviews, audits, or decisions to correct or exit misaligned associations. Nor does SEB publish a standalone lobbying-alignment report or detail criteria for assessing individual lobbying activities. This combination of Board-level oversight and stated processes, but absence of deeper monitoring detail or evidence of active alignment work, indicates moderate governance of climate-related lobbying.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Skandinaviska Enskilda Banken’s public information provides only limited insight into its climate-policy lobbying. The bank does name one specific piece of legislation it engages with – the EU Taxonomy Regulation – and makes broader references to related frameworks such as the EU Green Deal and SFDR, but it does not go on to list any other bills, reforms or jurisdictions it tries to influence. Its description of how it seeks to influence policy is similarly sparse: the main example is the placement of an employee on the EU Platform on Sustainable Finance, an advisory body to the European Commission, which signals an indirect mechanism for policy input but is the only clearly identified channel and target. Finally, the bank articulates only broad aspirations, such as supporting “increased transparency, comparability and standardisation in sustainable finance,” aligning its lending and investment portfolios with net-zero pathways, and encouraging governments to “raise their climate ambition,” without specifying concrete legislative changes, timelines or quantitative goals it wishes policymakers to adopt. Because disclosures stop at high-level intentions and provide just a single concrete policy reference and a single lobbying channel, overall transparency on climate lobbying remains limited.	D