Climate Lobbying Index

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Scotiabank articulates a formal policy governing its lobbying and political activities but provides only limited insight into how these processes align with its climate-change agenda. According to its disclosures, "Internally, we have a Policy for Communicating with Canadian Government Officials and Conducting Political Activities which outlines our expectations and requirements for employees who communicate with government officials," and employees "are reminded to speak with Government Affairs and Global Communications, as appropriate, prior to any such engagements that may involve discussions on issues that the Bank has already publicly addressed," indicating a pre-approval mechanism. The bank also states that it "frequently review[s] these engagements to ensure consistency with Bank held public policy positions," suggesting periodic oversight of its trade association engagements. While Scotiabank describes that it "engages in direct dialogue with policymakers, regulators, and government officials on issues of priority to the bank and financial services industry" and "participates in public policy discussions through financial sector and business associations," it does not clarify how these advocacy activities are monitored or aligned with its climate strategy. We found no evidence of a process to review or align direct and indirect lobbying specifically with the bank’s climate commitments, no disclosure of a climate-lobbying audit or third-party review, and no named individual or committee assigned to oversee lobbying alignment. Although climate-related risks are reported to the Board and committees such as the Risk Committee and Corporate Governance Committee, we found no evidence these bodies exercise oversight of lobbying or public-policy advocacy in service of its climate goals. View Sources	1

Overall Assessment

Analysis

Score

Limited

Scotiabank articulates a formal policy governing its lobbying and political activities but provides only limited insight into how these processes align with its climate-change agenda. According to its disclosures, "Internally, we have a Policy for Communicating with Canadian Government Officials and Conducting Political Activities which outlines our expectations and requirements for employees who communicate with government officials," and employees "are reminded to speak with Government Affairs and Global Communications, as appropriate, prior to any such engagements that may involve discussions on issues that the Bank has already publicly addressed," indicating a pre-approval mechanism. The bank also states that it "frequently review[s] these engagements to ensure consistency with Bank held public policy positions," suggesting periodic oversight of its trade association engagements. While Scotiabank describes that it "engages in direct dialogue with policymakers, regulators, and government officials on issues of priority to the bank and financial services industry" and "participates in public policy discussions through financial sector and business associations," it does not clarify how these advocacy activities are monitored or aligned with its climate strategy. We found no evidence of a process to review or align direct and indirect lobbying specifically with the bank’s climate commitments, no disclosure of a climate-lobbying audit or third-party review, and no named individual or committee assigned to oversee lobbying alignment. Although climate-related risks are reported to the Board and committees such as the Risk Committee and Corporate Governance Committee, we found no evidence these bodies exercise oversight of lobbying or public-policy advocacy in service of its climate goals.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Scotiabank discloses extensive information on every aspect of its climate-policy lobbying. It identifies multiple concrete regulatory initiatives it has engaged on, including Canada’s Office of the Superintendent of Financial Institutions “Consultation paper on Climate Change and Climate-Related Risks,” the draft “Guideline B-15: Climate Risk Management,” the International Sustainability Standards Board’s “IFRS S1 and IFRS S2” disclosure standards, as well as its advocacy through the Carbon Pricing Leadership Council and dialogue with the Ontario Securities Commission on climate-related disclosure rules. The Bank explains how it lobbies, citing public submissions to OSFI, “direct dialogue with policymakers, regulators, and government officials,” participation in industry associations such as the Canadian Bankers Association, and membership platforms like the Net-Zero Banking Alliance; specific targets named include OSFI, the Ontario Securities Commission, federal finance and environment ministries, and other Canadian regulators. It is also explicit about the outcomes it seeks: its OSFI submission presses for regulators to ensure firms are “assessing and appropriately managing climate-related risks”; through the CPLC it backs an expansion of carbon pricing “to maintain competitiveness, create jobs, encourage innovation and deliver emissions reductions”; and it advocates investment tax credits and other incentives to accelerate a clean-energy grid, the legal adoption of ISSB standards, and stronger disclosure and transition requirements for high-emitting sectors such as rail and oil sands. By detailing the policies addressed, the channels used and the specific legislative or regulatory changes pursued, the Bank demonstrates a comprehensive level of transparency in its climate lobbying activities.	4

Bank of Nova Scotia/The

Lobbying Transparency and Governance