Nordea Bank Abp

Nordea Bank Abp has articulated a governance framework for its climate-related lobbying, with Group Public Affairs (GPA) dedicated to "monitoring, analysing and advocating regarding new regulatory initiatives" and bound by "Nordea's Purpose, Values and Principles as set out in our Code of Conduct" and the Code of Conduct of the EU transparency register. Sustainable finance advocacy is managed by a Core Team "where each member is selected on the mandate of a GLT member," and "the CEO and GLT are responsible for any positions," ensuring top-level oversight of policy stances. This Core Team includes Nordea's representatives in "external associations" alongside a Group Sustainability (GS) representative who "is responsible for ensuring alignment of advocacy activities with Nordea's Group-wide sustainability strategy, including voluntary commitments," demonstrating that both direct and indirect lobbying are actively aligned with the bank's climate strategy. Nordea further commits that "refraining from participating in lobbying or advocacy activities aimed at weakening climate policy is part of the Nordea Group wide position statement on climate change." However, we found no evidence of a publicly available audit or a third-party review specifically assessing climate-lobbying alignment, nor of a formal board-level sign-off process on individual lobbying positions, which would provide additional transparency and accountability.