Credit Agricole SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Crédit Agricole S.A. provides a robust picture of the climate-policy issues on which it intervenes. It names several identifiable pieces of legislation or regulation it has engaged on, including the “EU Green Bond Standard Regulation,” France’s “future environmental regulation regarding the building sector (RT2020),” and the French “2015 Energy Transition Law,” as well as its input on the “taxonomy of green financial products.” The group also describes how it lobbies and through whom: it reports that “Crédit Agricole's ESG regulatory specialist … engaged in bilateral meetings with the co-legislators to share the bank's view of the proposal,” that “both political and technical discussions were held” with EU decision-makers, that it works indirectly via membership of the European association EACB and the French association AFEP, the latter of which “is in touch with the French government with regard to the legal texts to be published,” and that it co-founded the BBCA, whose representatives sit on a steering committee convened by France’s Minister of Housing and Sustainable Construction. Finally, the bank spells out the concrete outcomes it seeks: for the EU Green Bond file it wants the rules to “incentivise issuers to increase taxonomy-aligned investments and [ensure] the market will gradually converge towards the EU standard,” and through BBCA it aims to see whole-life-cycle carbon metrics embedded in RT2020 to enable “energy-plus” buildings. While many other climate targets the group discloses are internal rather than directed at lawmakers, these two stated policy objectives demonstrate a clear articulation of desired regulatory results. Together, these disclosures demonstrate a strong level of transparency on its climate-related lobbying activities.	3

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Crdit Agricole SA has established a structured governance framework to align both its direct and indirect lobbying efforts with its climate change strategy, anchored in a Lobbying Charter adopted in 2013 which is in the process of being revised for publication in 2023 and formalized through its Group Public Affairs department, which is responsible for lobbying on behalf of the Crdit Agricole Group and subject to the Internal Code of Business Conduct and the monitoring of its budget by the Finance department. This department regularly communicates key messages and positions advocated to internal bodies, including the Executive Committee, the Management Committee and the Specialised Committees of the Board of Directors, while the Societal Project department employs a specialist in charge of regulatory issues who contributes to ensuring that all the banks direct and indirect activities that influence policy are consistent with its overall climate change strategy and can be consulted by both business lines and Public Affairs to guide position-taking. This indicates strong oversight mechanisms and clear allocation of responsibility for policy alignment; however, we found no evidence of a publicly available climate-lobbying alignment report or a third-party audit dedicated to assessing its lobbying activities against its climate objectives.	3