National Australia Bank Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive National Australia Bank provides extensive, policy-specific detail about its climate-lobbying activity. It identifies a broad suite of measures it has engaged on, including submissions on the Corporate Emissions Reduction Transparency Scheme, the Climate Change (National Framework for Adaptation and Mitigation) Bill, consultations on Safeguard Mechanism reforms, the Nature Repair Market Bills, Australia’s Sustainable Finance Strategy exposure draft, the New Zealand Financial Sector (Climate-related Disclosures and Other Matters) Amendment Bill and global IFRS sustainability-reporting standards. The bank also explains how it engages: it notes “direct consultation with our customers, government and other stakeholders; participation in industry roundtables; and through contribution to the Australian Banking Association and other industry association submissions and statements,” and cites its own submissions to the Clean Energy Regulator, the Australian Treasury, the Department of Climate Change, Energy, Environment and Water, and New Zealand parliamentary committees, demonstrating both direct and association-based channels and naming the specific bodies targeted. Finally, NAB is clear about what it wants these engagements to achieve, advocating for “sectoral pathways, sustainable finance, emissions reduction, energy efficiency and electrification, climate disclosure and consistent reporting regimes, managing climate risk, just transition for workers and communities, natural disasters, climate resilience and biodiversity,” and stating its “support with no exceptions” for mandatory climate-related financial disclosure and for tightening emissions baselines in line with Australia’s Paris-aligned net-zero pathway. Together, these disclosures provide a high level of transparency across the policies addressed, the mechanisms employed and the outcomes sought. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate NAB demonstrates moderate climate-lobbying governance through a range of internal policies and procedures that seek to align its direct and indirect policy influence with its climate strategy. For instance, “NAB has an internal consultative process aimed to ensure that our direct and indirect activities that influence policy are consistent with the climate change area of focus in our Group Strategy and with our climate change strategy,” and under this process “representatives from relevant business units … and Group functions such as Risk, Corporate Affairs, Government Affairs and Legal meet together … to review policy changes and determine the relevance and impact of those policy changes” with “formal approval from relevant internal stakeholders … prior to the formal submission on proposed regulatory or policy changes.” The bank also commits that “NAB s Social Impact team regularly reviews the advocacy activities of NAB s industry associations to ensure continued alignment with the Paris Agreement goal” and maintains a “Stakeholder Advocacy and Action Management Standard Operating Procedure.” Despite these documented mechanisms for both direct engagement and industry association oversight, the company does not disclose a specific individual or formal body charged with reviewing or signing off on lobbying alignment, nor does it publish a dedicated climate-lobbying report or third-party audit detailing alignment outcomes. 2