Bankinter SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Bankinter provides an extensive and precise account of its climate-policy lobbying. It names multiple concrete measures it has engaged on, including the Spanish Climate Change Law and its implementing regulations, the Draft Royal Decree on reporting the financial impact of climate risks, the Preliminary Draft Law on corporate ESG reporting, and the transposition of the EU Sustainability Information Reporting Directive, as well as agreements that support Spain’s programme for energy-efficient building renovation through the Institute for Energy Diversification and Saving (IDAE). The bank is equally clear on how it seeks to influence these measures. It describes direct engagement such as supplying “opinions and recommendations” to the Ministry of the Environment on successive drafts of the Climate Change Law, participating in two Spanish Banking Association working groups that submit comments on draft regulations, and signing a collaboration protocol with IDAE to channel concessionary loans. It also discloses indirect mechanisms, for example leading the Spanish Climate Change Cluster in partnership with Foretica and the World Business Council for Sustainable Development. Each description identifies the public-sector body or forum targeted, demonstrating full transparency on both mechanism and interlocutor. Finally, the company sets out the results it seeks. It supports a regulatory pathway that delivers Spain’s net-zero goal by 2050, asks for intermediate milestones to be written into the Climate Change Law, advocates clearer disclosure requirements and additional time for smaller clients to provide data under forthcoming reporting rules, and promotes measures that improve the energy efficiency of the nation’s housing stock via dedicated finance. By spelling out these concrete policy objectives and the reasoning behind them, Bankinter shows a comprehensive level of transparency across all dimensions of its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Bankinter SA’s disclosures focus on the governance of sustainable product labelling rather than any process for governing lobbying activities. While the company notes that “All operations marked with a ‘Taxonomic Label’, ‘Green Label’ or ‘SLL Label’ are subject to an evaluation process in accordance with the standards provided for in these SFCC and the implementing documents” and describes a dual organisational structure in which a products committee and a Sustainable Labelling Unit review sustainability eligibility, we found no evidence that this framework extends to oversight of direct or indirect lobbying. The only indication of any climate-lobbying alignment policy is a public commitment: “Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […] Yes,” yet the company does not disclose who oversees this commitment, how alignment is monitored, or any process for managing its lobbying efforts in support of climate goals.	1