Direct Lobbying Transparency
| Overall Assessment | Comment | Score |
|---|---|---|
| Comprehensive | Aegon discloses a wide-ranging and detailed record of its climate-policy lobbying. It explicitly names numerous measures it has engaged on, including the EU Shareholder Rights Directive II, the EU Corporate Sustainability Reporting Directive and accompanying ESRS, the EU review of Solvency II, the EU Technical Expert Group work on taxonomy and green bond standards, the U.S. SEC’s proposed climate-disclosure amendments, and the NAIC Climate Risk Disclosure Survey, as well as its public endorsement of government implementation of the Paris Agreement. The company is equally clear about how and where it seeks to influence these policies: it cites direct “meetings with policymakers” at Dutch and EU level, submission of a “comment letter in response to the NAIC’s proposal,” and having “provided extensive feedback to the EU’s Technical Expert Group (TEG) on Sustainable Finance,” while also using collective channels such as the Dutch Insurers’ Association and an investor letter to “governments of the G7 and G20 nations.” Finally, Aegon sets out concrete outcomes it is pursuing, such as securing “quality, comparable data from investee companies,” achieving “coherence, consistency, and avoidance of duplication” across EU reporting rules, ensuring “interoperability between the ESRS and the… ISSB” standards, refining supplemental questions in the NAIC survey, advancing an ambitious EU taxonomy, and urging governments to “continue to support and fully implement the Paris Climate Agreement.” This combination of clearly identified policies, well-described engagement channels and targets, and specific policy goals demonstrates a comprehensive level of transparency around the company’s climate-related lobbying activities. | 4 |