Banco BPM SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Banco BPM discloses a structured internal process that can be applied to its external engagement, including any policy-related interactions, but the disclosure focuses on broad ESG decision-making rather than a dedicated climate-lobbying framework. The bank explains that “the ESG Operating Committee makes a formal proposition to the ESG Management Committee, which evaluates independently the initiative … [and] decides if the proposition matches the ESG position and goals of Banco BPM,” demonstrating a concrete escalation and approval mechanism to test alignment with its climate strategy. Oversight is clearly allocated, as “the ESG Management Committee is chaired by the CEO” and a newly created Board-level “Sustainability Committee offers support in the assessment and in-depth analysis of ESG issues related to the Bank’s operations and in the approval of strategic guidelines and policies on sustainability, including … the fight against climate change,” indicating top-level governance of these engagement decisions. This shows that senior committees and named individuals review and approve climate-related engagement before it proceeds, which indicates moderate governance. However, the company does not disclose how this process specifically covers direct lobbying activities with policymakers or the oversight of indirect lobbying through trade associations, nor does it publish any alignment assessment or audit of its lobbying positions, so the breadth and transparency of its lobbying governance remain limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Banco BPM discloses a structured internal process that can be applied to its external engagement, including any policy-related interactions, but the disclosure focuses on broad ESG decision-making rather than a dedicated climate-lobbying framework. The bank explains that “the ESG Operating Committee makes a formal proposition to the ESG Management Committee, which evaluates independently the initiative … [and] decides if the proposition matches the ESG position and goals of Banco BPM,” demonstrating a concrete escalation and approval mechanism to test alignment with its climate strategy. Oversight is clearly allocated, as “the ESG Management Committee is chaired by the CEO” and a newly created Board-level “Sustainability Committee offers support in the assessment and in-depth analysis of ESG issues related to the Bank’s operations and in the approval of strategic guidelines and policies on sustainability, including … the fight against climate change,” indicating top-level governance of these engagement decisions. This shows that senior committees and named individuals review and approve climate-related engagement before it proceeds, which indicates moderate governance. However, the company does not disclose how this process specifically covers direct lobbying activities with policymakers or the oversight of indirect lobbying through trade associations, nor does it publish any alignment assessment or audit of its lobbying positions, so the breadth and transparency of its lobbying governance remain limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Banco BPM provides only limited insight into its climate-related lobbying. It references broad policy frameworks such as the EU Green Deal, the National Recovery and Resilience Plan, the EU Taxonomy and the European Commission’s Action Plan on sustainable finance, showing that it is aware of these initiatives but it does not identify any specific law or regulation it has tried to influence. The bank hints at potential avenues of engagement—participation in working groups during consultations on new legislation and ESG-focused meetings with the European Central Bank—yet it offers no detail on who was approached, when or how often, nor does it describe other concrete mechanisms such as letters, formal submissions or coalition activity. Likewise, its disclosures remain at the level of general aspirations, stating aims like supporting the transition to a low-emission economy and facilitating NRRP-related financing, without spelling out the precise policy changes or legislative outcomes it seeks. Collectively, this leaves only a partial picture of Banco BPM’s climate lobbying transparency.	D