Societe Generale SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Societe Generale has provided a comprehensive level of transparency regarding its climate-policy lobbying. It clearly identifies the specific regulations it engaged with, naming policies such as the “Taxonomy on sustainable activities,” the “Corporate Sustainability Reporting Directive (CSRD),” the “European Union Green Bond Standard (EuGBS),” the “Sustainable Finance Disclosure Regulation (SFDR),” and EFRAG’s standards on CSRD disclosures. The bank outlines detailed lobbying mechanisms, noting that engagement is conducted through “bilateral or collective (together with trade associations) actions,” including “meetings with policymakers at national or EU level,” “contribution to consultations or hearings,” “preparation of position papers, opinion polls, open letters and other communication or information material,” and “commissioning and carrying out of research,” targeting entities such as the European Commission, ESMA, and EBA. It also articulates clear outcomes it seeks from these engagements, advocating for “well-coordinated approaches at both the EU and the global levels to catalyse more investments towards transitioning activities,” aiming to “increase disclosures of more relevant, verifiable, faithful, understandable, and comparable sustainability-related information,” and ensuring that “sustainable finance regulatory initiatives for the financial sector are not defined in isolation but pay attention to consequences on impacted stakeholders.” Additionally, it has set specific objectives such as reducing its exposure to oil and gas production by 20% by 2025 and achieving a CO2 emission intensity target of 125 gCO2 per kWh by 2030.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Societe Generale has implemented a strong governance framework for climate-related lobbying that integrates both direct advocacy and indirect engagement through trade associations. The bank requires that “positions are driven by decisions taken by the business lines with the approval of the Chief Sustainability Officer (CSO)” and mandates that the Public Affairs Department, with “2 FTEs assigned to sustainable finance regulations,” work with the CSO and business lines to ensure “positions are discussed and approved before any advocacy occurs.” A biweekly Steering Committee, comprising “all business and support functions with regulatory responsibilities (Risk, Compliance, Finance, CSO) and all public affairs officers,” regularly reviews CSR topics, and the internal Code stipulates that “any advocacy activity is approved by the Head of BU/SU and the Public Affairs Director,” with approximately 50 Advocacy Correspondents ensuring compliance. The bank also addresses discrepancies in trade association positions by committing to “try to influence the position,” request that “not every member shares the associative position,” or “publish… our own divergent position,” demonstrating active management of indirect lobbying. Oversight is clearly assigned to senior executives, including the CSO and the Public Affairs Director, yet we found no evidence of a publicly available climate-lobbying audit or board-level review dedicated to assessing the alignment of its lobbying activities with its climate change strategy.	3