Bendigo & Adelaide Bank Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Bendigo & Adelaide Bank sets out a defined but relatively limited process for overseeing its climate-related advocacy. The company explains that “our Bank will receive, review, and respond to requests from government… on a case-by-case basis” and that these engagements, together with those conducted “via industry groups (primarily the Australian Bankers Association and Business Council of Australia),” are “tracked by the Corporate Affairs team and reported on via the monthly Corporate Affairs Report which is viewed by the Executive, Board, and other senior leaders across the Group.” This monthly reporting, coupled with the statement that staff “are bound by the Group’s Communications Policy which outlines who is an authorised spokesperson and their responsibilities” and “ensures public comments are aligned and approved,” shows that the Bank has a mechanism to monitor direct advocacy and keep it consistent with corporate positions on climate. The disclosure also names oversight bodies—the Executive Committee and the Board—highlighting that climate matters are escalated, as “the Board’s Board Audit Committee receives scheduled half year updates on progress on our Climate Change Action plan with annual reporting to the full Board.” However, the company does not disclose a systematic review of the climate-policy positions of its trade associations, nor any process for correcting or exiting misaligned groups, and no stand-alone climate-lobbying audit or third-party review is referenced. Overall, while the existence of tracking, reporting, and board-level visibility indicates moderate governance, the absence of detailed monitoring of indirect lobbying and of a published alignment assessment limits the strength of its framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Bendigo & Adelaide Bank sets out a defined but relatively limited process for overseeing its climate-related advocacy. The company explains that “our Bank will receive, review, and respond to requests from government… on a case-by-case basis” and that these engagements, together with those conducted “via industry groups (primarily the Australian Bankers Association and Business Council of Australia),” are “tracked by the Corporate Affairs team and reported on via the monthly Corporate Affairs Report which is viewed by the Executive, Board, and other senior leaders across the Group.” This monthly reporting, coupled with the statement that staff “are bound by the Group’s Communications Policy which outlines who is an authorised spokesperson and their responsibilities” and “ensures public comments are aligned and approved,” shows that the Bank has a mechanism to monitor direct advocacy and keep it consistent with corporate positions on climate. The disclosure also names oversight bodies—the Executive Committee and the Board—highlighting that climate matters are escalated, as “the Board’s Board Audit Committee receives scheduled half year updates on progress on our Climate Change Action plan with annual reporting to the full Board.” However, the company does not disclose a systematic review of the climate-policy positions of its trade associations, nor any process for correcting or exiting misaligned groups, and no stand-alone climate-lobbying audit or third-party review is referenced. Overall, while the existence of tracking, reporting, and board-level visibility indicates moderate governance, the absence of detailed monitoring of indirect lobbying and of a published alignment assessment limits the strength of its framework.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Bendigo & Adelaide Bank provides a limited but concrete window into its climate-policy lobbying. It discloses the exact legislation it engaged on—the “Australian Local Power Agency Bill 2021” and the related “Australian Local Power Agency (Consequential Amendments) Bill 2021”—demonstrating clarity about which measures it sought to influence. The Bank also explains one clear method and target, stating that it “submitted letters of support to the committee” overseeing the parliamentary inquiry into the bill, which identifies both the mechanism (letters of support) and the recipient (the government committee). Beyond this, lobbying activity is described only in broad terms such as participation in Australian Banking Association working groups and attendance at industry events, without naming the government bodies or decision makers involved. As to the result it hoped to achieve, the Bank notes its “strong support for the bill,” signalling a desire for the legislation to pass but offering no detail on specific amendments, targets, or policy provisions it advocated. Overall, while the company does reveal the core bill it supported and how it registered that support, it provides little insight into other mechanisms or the precise policy outcomes it sought, leaving its lobbying transparency modest.	D