ASR Nederland NV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	ASR Nederland discloses that “Public Affairs of a.s.r. monitors developments in the area of legislation and regulations while providing appropriate answers in its political contacts” and that “all public affairs, lobbying and political network activities are carried out in line with the Code of Conduct of the Dutch Association for Public Affairs (BVPA),” which signals the existence of an internal function that both conducts and supervises lobbying activities and a stated requirement to follow an external code of conduct. The same section explains that “Public Affairs supports the operational disciplines within a.s.r. on the regulatory framework and political strategies and monitors these topics,” indicating a recurring review step for lobbying engagements. However, the disclosures do not identify a board committee, executive, or named individual charged specifically with overseeing lobbying alignment, nor do they describe any formal process to test whether direct or indirect advocacy is consistent with the company’s climate strategy, to review trade-association positions, or to publish lobbying-alignment assessments. The governance narrative around climate (e.g., “Within the Executive Board (EB), the CEO has final responsibility for the sustainability theme”) outlines broader ESG oversight but does not connect this oversight to policy-influencing activities. Overall, the company provides limited information about how lobbying is governed and virtually none on how climate-related lobbying alignment is assured, so only a basic level of lobbying-governance disclosure is evident. View Sources	D

Overall Assessment

Analysis

Score

Limited

ASR Nederland discloses that “Public Affairs of a.s.r. monitors developments in the area of legislation and regulations while providing appropriate answers in its political contacts” and that “all public affairs, lobbying and political network activities are carried out in line with the Code of Conduct of the Dutch Association for Public Affairs (BVPA),” which signals the existence of an internal function that both conducts and supervises lobbying activities and a stated requirement to follow an external code of conduct. The same section explains that “Public Affairs supports the operational disciplines within a.s.r. on the regulatory framework and political strategies and monitors these topics,” indicating a recurring review step for lobbying engagements. However, the disclosures do not identify a board committee, executive, or named individual charged specifically with overseeing lobbying alignment, nor do they describe any formal process to test whether direct or indirect advocacy is consistent with the company’s climate strategy, to review trade-association positions, or to publish lobbying-alignment assessments. The governance narrative around climate (e.g., “Within the Executive Board (EB), the CEO has final responsibility for the sustainability theme”) outlines broader ESG oversight but does not connect this oversight to policy-influencing activities. Overall, the company provides limited information about how lobbying is governed and virtually none on how climate-related lobbying alignment is assured, so only a basic level of lobbying-governance disclosure is evident.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	ASR Nederland provides only limited insight into its climate-related lobbying. The company refers to broad policy areas such as the Dutch government’s planned 25 % CO₂-reduction target, the future ban on coal-fired power stations and the EU Energy Performance of Buildings Directive, but it does not clearly identify any specific bill, regulation or rule on which it has actually lobbied, nor does it state that these are the only policies it engages on. It describes high-level methods—participation in public policy consultations, membership of the Dutch Association of Insurers, and involvement in platforms such as the Platform Carbon Accounting Financials—but it does not say whether these activities involve letters, meetings or submissions, and it does not name the policymaking bodies, ministries or legislators it attempts to influence. The company’s stated objectives are similarly generic: supporting the transition to a net-zero world, encouraging renewable energy uptake, and raising awareness of climate-change risks, without specifying the legislative amendments, regulatory thresholds or timetables it seeks. Because the disclosures remain general across all three dimensions—policies, mechanisms and outcomes—the overall level of transparency on climate lobbying is low.	D