Shinhan Financial Group Co Ltd

Shinhan Financial Group describes a high-level structure that touches on oversight of external engagement but provides only limited insight into how lobbying is specifically governed. The company states that "ESG-related working-level organizations report to the upper consultative body regularly a month and to the ESG Strategy Committee, a committee within the BOD, 4 to 6 times a year. Through this ESG governance, the group's climate change strategy is consistently applied," and confirms that it has "a public commitment ... to conduct your engagement activities in line with the goals of the Paris Agreement." These disclosures indicate that the Board-level ESG Strategy Committee has some responsibility for reviewing climate-related engagement activities, suggesting an internal review step and an intention to align such engagement with climate goals. However, the evidence does not disclose any concrete mechanism that differentiates or monitors direct versus indirect lobbying, no description of how trade-association positions are assessed or corrected, and no published review or audit of lobbying alignment. Therefore, while the presence of a Board committee overseeing engagement indicates some governance, the company does not disclose a detailed process for managing or auditing climate lobbying activities.