UniCredit SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	UniCredit provides an exceptionally detailed picture of its climate-policy advocacy. It names a wide range of specific measures it has engaged on, including the “EU Emission Trading System review,” “Pillar 3 disclosures on ESG risks in accordance with Article 449a CRR,” the “Creation of the EU standard for green bonds,” the “Taxonomy Regulation and relevant Delegated Acts,” and other initiatives covering risk management, corporate ESG disclosure and sustainable corporate-governance rules. The bank also spells out how and with whom it lobbies, describing that it “provided feedback to the trade industry papers and attended the meetings with the EC’s DG CLIMA and ESMA,” “attended the EBA’s public hearing and requested additional details,” and held “meeting[s] with representatives of the European Parliament … and with the representatives of Member States,” thereby identifying both the mechanisms (feedback submissions, public hearings, bilateral meetings) and the concrete targets (DG CLIMA, ESMA, EBA, MEPs, national delegates). Finally, UniCredit is explicit about the outcomes it seeks: it opposed limits on financial-sector participation in the EU ETS because they would “undermine the ability of many companies to manage their risks” and could “negatively affect the investments in new technologies”; it supported Pillar 3 ESG disclosures “to ensure a proper disclosure”; it advocated that the green-bond standard allow “full-grandfathering” and “20 percent of flexibility” for certain projects; and it pushes for the “finalization of EU Taxonomy” and a “sustainable finance supporting factor linked to the EU taxonomy.” By detailing the policies, the engagement channels and the precise policy positions, the company demonstrates a comprehensive level of transparency around its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	UniCredit SpA has established a structured process to ensure its engagement activities align with its climate change strategy, embedding “20 key workstreams” in its Group ESG Roadmap that are led by colleagues across functions acting as “ESG Reference points for the entire organization.” Its public positioning on climate-related advocacy follows “a structured internal process that starts with a bottom-up analysis of rules and regulation performed by relevant company structures … followed by a top-down alignment with the overall Group guidelines,” and responsibilities are split between the Group Regulatory Affairs department, which is described as the “owners of the formal institutional positioning vis-à-vis regulators and public institutions,” and Group Sustainability, referred to as “the knowledge point on climate change.” However, the company does not disclose any process for reviewing or auditing this lobbying alignment, nor does it identify a named individual or formal oversight body responsible for governance, and we found no evidence of specific measures to manage indirect lobbying through trade or industry associations.	2