CIMB Group Holdings Bhd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	CIMB Group has established a specific process to align its climate lobbying with the Paris Agreement ambition, stating that it “endeavour[s] to ensure that any lobbying activities relevant to climate policy is consistent with our stated objectives in delivering the ambition of the Paris Agreement” and setting out an escalation process that “entails engaging with said association with a clear timeline for actions be taken, or if unsuccessful we may issue a public statement distancing CIMB from the misalignment, or leave the trade association.” This indicates that the bank actively manages indirect lobbying through trade associations and extends to direct advocacy for national and company-level emission reduction plans, but we found no evidence of a named individual or formal body tasked with overseeing or reviewing these lobbying activities. Moreover, while the Group Sustainability and Governance Committee convenes quarterly to provide oversight on broader sustainability matters, the company does not disclose any specific governance structure, board sign-off process, or routine audit dedicated to climate lobbying. This suggests moderate governance, with clear alignment policies and escalation mechanisms in place but limited transparency on oversight responsibility and monitoring of direct lobbying actions. View Sources	C

Overall Assessment

Analysis

Score

Moderate

CIMB Group has established a specific process to align its climate lobbying with the Paris Agreement ambition, stating that it “endeavour[s] to ensure that any lobbying activities relevant to climate policy is consistent with our stated objectives in delivering the ambition of the Paris Agreement” and setting out an escalation process that “entails engaging with said association with a clear timeline for actions be taken, or if unsuccessful we may issue a public statement distancing CIMB from the misalignment, or leave the trade association.” This indicates that the bank actively manages indirect lobbying through trade associations and extends to direct advocacy for national and company-level emission reduction plans, but we found no evidence of a named individual or formal body tasked with overseeing or reviewing these lobbying activities. Moreover, while the Group Sustainability and Governance Committee convenes quarterly to provide oversight on broader sustainability matters, the company does not disclose any specific governance structure, board sign-off process, or routine audit dedicated to climate lobbying. This suggests moderate governance, with clear alignment policies and escalation mechanisms in place but limited transparency on oversight responsibility and monitoring of direct lobbying actions.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
None	CIMB Group Holdings Bhd has provided no transparency around its climate-related lobbying activities. The company does not name any specific climate policies, laws, or regulations it has engaged with and instead focuses on internal initiatives and partnerships. It also fails to disclose any lobbying mechanisms or identify policymaking targets, offering only vague references to “advocacy,” engagement in forums, and participation in working groups. Furthermore, CIMB does not specify any policy outcomes it seeks to achieve through lobbying, concentrating solely on its own emission reduction and sustainability goals. As such, no evidence was found of CIMB engaging in climate policy lobbying.	E