BPER Banca SPA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	BPER Banca SPA provides a limited governance framework for its climate-related engagement, noting that “BPER’s Head of ESG Strategy is in the European Banking Federation working group that monitors the legal development of the EU Taxonomy” and explaining that “the focus of the activities is towards the collection of relevant data and experiences from different banking sector participants, so that it can be put forward consistent and well-substantiated positions before the regulators.” The bank also confirms “Yes” in response to having “a public commitment or position statement to conduct … engagement activities in line with the goals of the Paris Agreement.” This indicates active alignment through trade associations and a public pledge on climate-concordant advocacy, but the company does not disclose a formal lobbying policy or process for monitoring and managing lobbying activities, does not delineate oversight responsibilities beyond the Head of ESG Strategy’s engagement, and makes no reference to governance of its direct lobbying channels. View Sources	C

Overall Assessment

Analysis

Score

Moderate

BPER Banca SPA provides a limited governance framework for its climate-related engagement, noting that “BPER’s Head of ESG Strategy is in the European Banking Federation working group that monitors the legal development of the EU Taxonomy” and explaining that “the focus of the activities is towards the collection of relevant data and experiences from different banking sector participants, so that it can be put forward consistent and well-substantiated positions before the regulators.” The bank also confirms “Yes” in response to having “a public commitment or position statement to conduct … engagement activities in line with the goals of the Paris Agreement.” This indicates active alignment through trade associations and a public pledge on climate-concordant advocacy, but the company does not disclose a formal lobbying policy or process for monitoring and managing lobbying activities, does not delineate oversight responsibilities beyond the Head of ESG Strategy’s engagement, and makes no reference to governance of its direct lobbying channels.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	BPER Banca offers a focused but narrow account of its climate-policy lobbying. It identifies a single concrete policy, the EU’s Sustainable Finance Taxonomy, describing it under “Climate change mitigation” and “Climate-related reporting.” The bank explains how it engages: “BPER's Head of ESG Strategy is in the European Banking Federation working group that monitors the legal development of the EU Taxonomy … [and] reports a final document to the European Commission,” which clearly sets out both the mechanism (participation in an industry working group) and the target (the European Commission). The company also states that the objective is to bring “consistent and well-substantiated positions before the regulators,” ensuring the banking sector’s capabilities are reflected in the Taxonomy, and links this to its Net-Zero Banking Alliance commitments. Nevertheless, the disclosure covers only this single policy, gives just one example of mechanism and target, and outlines only one desired outcome, so the overall transparency of its climate-related lobbying remains limited.	D