Sustainable Finance Lobbying Overview: AXA and its subsidiaries, AXA Investment Managers (AXA IM) and AllianceBernstein, appear to have had significant engagement on sustainable finance policy, with mostly positive positions. While engagement from AXA and AXA IM in the EU appears to be generally supportive of sustainable finance policy, engagement from AllianceBernstein in the US is more mixed.

Top-Line Messaging on Sustainable Finance Policy: AXA has advocated for action to achieve net-zero by 2050 and has expressed support for reform of the financial sector to address short-termism in markets. In 2022, AXA signed a joint statement advocating for the post-2020 global biodiversity framework to mandate the alignment of financial flows with biodiversity goals. AXA and AXA IM have stated support for the EU’s Action Plan on Sustainable Finance in their sustainability reporting.

Position on Regulated Corporate ESG Disclosure: AXA and AXA IM appear supportive of improving regulated corporate disclosure on both climate and biodiversity. AXA stated broad support for increased ambition on mandatory sustainability reporting in its 2022 Climate and Biodiversity Report. During COP15 in December 2022, AXA signed a joint statement calling on the post-2020 global biodiversity framework to include disclosure of nature-related impacts and dependencies. AXA IM has stated support for the EU’s Non-Financial Reporting Directive (NFRD) in its website and co-signed an investor statement urging EU policymakers to increase the ambition of the Corporate Sustainability Reporting Directive (CSRD) in 2021. AXA IM further supported mandatory implementation of the TCFD for occupational pension schemes in response to the UK Department for Work and Pensions’ consultation in 2021.

AllianceBernstein has taken mixed positions on the SEC Climate Disclosure Rule. In response to the 2021 SEC request for input, AllianceBernstein appeared strongly supportive of action on climate disclosures, including the reporting of Scope 3 emissions. However, after the SEC published its proposed rule in 2022, AllianceBernstein took a more mixed position, broadly supporting the rule but advocating for less ‘prescriptive’ Scope 3 disclosure and a longer implementation period.

Position on Taxonomies: In 2021, AXA IM stated broad support for the EU taxonomy on its website. AXA has also supported the taxonomy, and advocated for the extension of the taxonomy to include ‘transition’ efforts in its 2022 Climate and Biodiversity Report. However, it is sometimes unclear whether AXA is advocating to widen the 'transition' category in the current 'green' framework, which would weaken the policy, or whether advocating for a separate category, which would be aligned with the position of the Platform on Sustainable Finance. In a media article in 2021, AXA’s CEO Thomas Buberl, appeared to endorse the possible of the taxonomy criteria to include nuclear energy as ‘green’. However, in 2022, Euractiv reported that AXA was opposing this weakening of the criteria.

Position on ESG Standards/Labels/Benchmarks: In its 2018 Responsible Investment Review, AXA IM appeared to support the need for green bond standards, and AllianceBernstein stated support for the EU Green Bond Standard in a 2021 blog.

Position on Incorporating ESG Factors Into Investment Duties: In its 2021 Article 173/TCFD report, AXA IM stated broad support for the EU’s Sustainable Finance Disclosure Regulation (SFDR). In AXA’s 2022 Climate and Biodiversity Report, it described the SFDR without taking a clear position.

In 2020, AXA's subsidiary AllianceBernstein, strongly opposed proposed Trump administration-era rollbacks by the US Department of Labor and the SEC that would limit fiduciaries' voting on ESG issues and shareholder rights, respectively. However, AllianceBernstein offered a mixed position on the reversal of the Department of Labor rule under the Biden administration in 2021, supporting efforts to remove barriers for plan fiduciaries to consider ESG in decision making, but asking the Department to remove specific references to ESG from rule language. In a May 2022 response to the Department of Labor’s RFI on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk, AllianceBernstein did not support elevating climate risks in investor decision-making or a requirement for plan fiduciaries to report on climate risk.

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: AXA appears to have had limited engagement on incorporating ESG issues into risk management regulation, but appears broadly supportive where it has engaged. In its 2022 Climate and Biodiversity Report, AXA appeared to state broad support for climate stress tests in the UK and EU. AXA IM signed an Investor Agenda statement in 2022 that called for “coordinating and driving consistency across global financial regulation in the areas of mandatory climate risk disclosure and prudential risk supervision”.

Transparency: AXA lacks a clear dedicated disclosure of its positions, but has listed policies it is engaged on its 'Public Affairs' webpage and has separately provided details of some policy positions in its 2022 Climate and Biodiversity Report. AXA has listed some of its industry association memberships on its website, with no further detail on indirect governance. The list provided is non-exhaustive and does not cover memberships to associations including Insurance Europe, the Association of British Insurers and the American Council of Life Insurers