Societe Generale SA

Societe Generale has implemented a strong governance framework for climate-related lobbying that integrates both direct advocacy and indirect engagement through trade associations. The bank requires that "positions are driven by decisions taken by the business lines with the approval of the Chief Sustainability Officer (CSO)" and mandates that the Public Affairs Department, with "2 FTEs assigned to sustainable finance regulations," work with the CSO and business lines to ensure "positions are discussed and approved before any advocacy occurs." A biweekly Steering Committee, comprising "all business and support functions with regulatory responsibilities (Risk, Compliance, Finance, CSO) and all public affairs officers," regularly reviews CSR topics, and the internal Code stipulates that "any advocacy activity is approved by the Head of BU/SU and the Public Affairs Director," with approximately 50 Advocacy Correspondents ensuring compliance. The bank also addresses discrepancies in trade association positions by committing to "try to influence the position," request that "not every member shares the associative position," or "publish... our own divergent position," demonstrating active management of indirect lobbying. Oversight is clearly assigned to senior executives, including the CSO and the Public Affairs Director, yet we found no evidence of a publicly available climate-lobbying audit or board-level review dedicated to assessing the alignment of its lobbying activities with its climate change strategy.