Hang Seng Bank Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Hang Seng Bank describes a structured governance framework that touches on how climate-related public-policy engagement is handled, indicating more than a minimal approach but still lacking the depth of a fully detailed lobbying-alignment system. The Board “takes overall responsibility for our ESG strategy” and delegates day-to-day oversight to an ESG Steering Committee that is explicitly mandated to “integrate climate-related considerations into the strategy, set climate-related corporate targets, manage public policy engagement that may impact the climate, and assess climate-related risks and opportunities.” This demonstrates that a named management body oversees climate-related lobbying activities and that a process exists to monitor them. In addition, the company confirms it has “a public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement,” signalling an intention to align advocacy with its climate objectives. However, the disclosure stops short of explaining how alignment is tested or enforced: there is no description of systematic reviews of direct lobbying positions, no discussion of trade-association evaluations, and no published climate-lobbying audit or report. As such, while oversight responsibilities and a high-level commitment are in place, the company does not disclose the detailed monitoring mechanisms, alignment assessments, or corrective actions that would indicate a more comprehensive governance approach. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Hang Seng Bank describes a structured governance framework that touches on how climate-related public-policy engagement is handled, indicating more than a minimal approach but still lacking the depth of a fully detailed lobbying-alignment system. The Board “takes overall responsibility for our ESG strategy” and delegates day-to-day oversight to an ESG Steering Committee that is explicitly mandated to “integrate climate-related considerations into the strategy, set climate-related corporate targets, manage public policy engagement that may impact the climate, and assess climate-related risks and opportunities.” This demonstrates that a named management body oversees climate-related lobbying activities and that a process exists to monitor them. In addition, the company confirms it has “a public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement,” signalling an intention to align advocacy with its climate objectives. However, the disclosure stops short of explaining how alignment is tested or enforced: there is no description of systematic reviews of direct lobbying positions, no discussion of trade-association evaluations, and no published climate-lobbying audit or report. As such, while oversight responsibilities and a high-level commitment are in place, the company does not disclose the detailed monitoring mechanisms, alignment assessments, or corrective actions that would indicate a more comprehensive governance approach.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Hang Seng Bank provides only cursory insight into its climate-related public-policy engagement. It notes that it has “joined the Climate Change Business Forum Advisory Group,” become “a signatory to the Carbon Neutrality Partnership organised by the Environment Bureau of Hong Kong SAR Government,” and taken part in the “Energy Saving Charter 2021” scheme, but it does not indicate that any of these activities involved efforts to influence specific legislation or regulation, nor does it name any bill, regulation, or rule it has lobbied. The bank similarly omits any description of how it seeks to influence policy: there is no reference to letters, meetings, submissions, or other direct or indirect lobbying channels, and no policymaking bodies or officials are identified as targets. Finally, while the bank states a broad ambition “to support our community in transition to a low-carbon economy and carbon neutrality with sustainable financial solutions,” it does not articulate concrete policy changes or regulatory outcomes it is advocating for. Overall, the disclosure signals general support for government climate goals but offers very limited transparency about any lobbying activities, mechanisms, or desired policy outcomes.	D