Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Moderate |
DGB Financial Group discloses that its climate-related external engagement is overseen by a tiered governance structure, stating that “DGB Financial Group manages ESG issues, including climate change, through a working-level and executive-level councils and the highest ESG decision-making body under its board, the ESG Committee.” The company explains that “the ESG working-level council and ESG management council frequently consult on ESG issues and response strategies, and report to the ESG committee,” and that this committee “reviews the group’s ESG strategies and directions, deliberates on agendas, and manages implementation status and performance.” By describing how engagement activities are channelled through these bodies to ensure they are “consistent with your climate commitments and/or climate transition plan,” the disclosure provides a concrete process and a named oversight body, indicating moderate governance of lobbying alignment. However, the evidence does not detail how the company distinguishes between its own direct advocacy and membership-based or trade-association lobbying, nor does it outline any mechanisms for assessing or correcting misaligned positions in those forums. We found no reference to publishing a lobbying-alignment review, setting criteria for association participation, or taking action such as engagement or withdrawal where misalignment occurs. Consequently, while the presence of an ESG Committee that reviews external engagement indicates meaningful oversight, the absence of disclosure on monitoring indirect lobbying or producing a public alignment assessment leaves important elements of a robust climate-lobbying governance framework undisclosed.
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