Industrial & Commercial Bank of China Ltd – Lobbying Governance & Transparency

Sign up to access all our data and the evidence and analysis underlying our overall scores. Once you've created an account, we'll get in touch with further details:

Lobbying Governance

Overall Assessment	Analysis	Score
None	Industrial & Commercial Bank of China Ltd has a detailed governance framework for green finance and climate risk management, but we found no evidence of any internal mechanisms or oversight structures specific to lobbying activities or policy advocacy. For example, the bank describes that “The Bank strengthened the top-level design and strategic promotion of green finance” and that “The Board of Directors of the Bank attaches great importance to the work on green finance,” yet there is no reference to how the company’s lobbying, direct or indirect, is monitored, managed, or aligned with its climate objectives. The disclosures focus on a Green Finance (ESG and Sustainable Finance) Committee, the “Regulation on All Types of Risk Management (Version 2022)” which includes a chapter on “climate risk management,” and extensive three-lines-of-defense processes for climate risk, but the company does not disclose any policy, review process, or named individual or body that oversees lobbying alignment with sustainability or climate policy goals. View Sources	E

Overall Assessment

Analysis

Score

None

Industrial & Commercial Bank of China Ltd has a detailed governance framework for green finance and climate risk management, but we found no evidence of any internal mechanisms or oversight structures specific to lobbying activities or policy advocacy. For example, the bank describes that “The Bank strengthened the top-level design and strategic promotion of green finance” and that “The Board of Directors of the Bank attaches great importance to the work on green finance,” yet there is no reference to how the company’s lobbying, direct or indirect, is monitored, managed, or aligned with its climate objectives. The disclosures focus on a Green Finance (ESG and Sustainable Finance) Committee, the “Regulation on All Types of Risk Management (Version 2022)” which includes a chapter on “climate risk management,” and extensive three-lines-of-defense processes for climate risk, but the company does not disclose any policy, review process, or named individual or body that oversees lobbying alignment with sustainability or climate policy goals.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
None	Industrial & Commercial Bank of China Ltd provides extensive narrative about its own green-finance products and internal governance, but it offers no transparency on climate-policy lobbying. The disclosures do not name any specific laws, regulations or government programmes the bank has tried to influence, nor do they even outline broad categories of climate policy it actively engages on. Likewise, there is no description of how the bank would attempt to influence policymakers—no mention of meetings, written submissions, membership of advocacy coalitions, or other channels directed at particular government entities. Finally, the reports do not state any policy changes, amendments, or regulatory outcomes the bank hopes to secure through public-policy engagement; the only objectives cited relate to its own lending targets and disclosure practices. In short, we found no evidence that ICBC discloses climate-related lobbying activities, mechanisms or intended outcomes.	E