Sustainable Finance Lobbying Overview: Crédit Agricole appears to be actively engaged on sustainable finance policy, with mixed positions. Crédit Agricole and its asset management subsidiary Amundi appear to independently engage with policy, although both with mixed positions, addressing a range of different sustainable finance policy strands and with some differing positions.

Top-line Messaging on Sustainable Finance Policy: Crédit Agricole has stated support for the role of finance in reaching the goals of the Paris Agreement, and appears to support reform to make the financial sector more sustainable. Amundi has supported action to keep global temperature rise to 1.5C and to reach net-zero by 2050. In joint letters, Amundi has advocated for action to achieve net-zero by 2050 and has also advocated for the post-2020 global biodiversity framework to mandate the alignment of financial flows with biodiversity goals. In meetings with the European Commission in 2022, Amundi further highlighted the need for financial institutions to align their actions with their targets.

Position on Taxonomies: In feedback to the Commission on the Renewed Strategy in 2020, Crédit Agricole advocated for the inclusion of more transitional activities in the taxonomy but opposed the expansion of the taxonomy to cover environmentally harmful activities. In response to the Commission in 2021, Crédit Agricole did recommend a one-year delay to the taxonomy’s implementation after the disclosures of non-financial companies are implemented. In meetings with the Commission Director General in 2022, Amundi recommended a “dynamic approach” to the taxonomy, which appeared to suggest the support of a weaker definition of green activities.

Position on Regulated Corporate ESG Disclosure: In a consultation response to the European Commission in 2020, Amundi appeared to support an ambitious review of the Non-Financial Reporting Directive (NFRD). In joint statements in 2021, Amundi advocated for mandatory implementation of the Task Force on Climate-related Financial Disclosures (TCFD), and for EU policymakers to increase the scope of the Corporate Sustainability Reporting Directive (CSRD, which replaced the NFRD) in order to respond to the needs of investors in Sustainable Finance Disclosure Regulation (SFDR) disclosures. In response to the European Financial Reporting Advisory Group (EFRAG) in 2022, on the proposal for the European Sustainability Requirement Standards under the CSRD, Crédit Agricole argued against the “volume and complexity” of the disclosure requirements. In the same consultation, subsidiary Crédit Agricole Assurances similarly argued against the level of sector-agnostic disclosures and suggested some were too granular. In response to the International Sustainability Standards Board (ISSB) on the Climate and Sustainability Disclosure Drafts in 2022, Amundi advocated for further ambition including a double materiality approach. However, in a research paper in 2022, Amundi suggested there was an issue in encouraging asset owners and managers to go beyond scope 1 and 2 disclosures, highlighting challenges with disclosing scope 3 emissions and portfolio alignment. In a joint statement in 2022, Amundi did advocate for the assessment and disclosure of nature-related impacts and dependencies.

Position on ESG Standards, Labels & Benchmarks: In feedback to the Commission in 2020, both Crédit Agricole and Amundi supported the need for EU level verification of the EU Green Bond Standard (GBS). In 2020, an article on the EFAMA website featured Thierry Bogaty (Head of ESG Strategy at Amundi) stating top-line support for the EU Ecolabel but arguing for weaker green criteria on the basis that more investments would be eligible.

Position on Integrating ESG into Investor Duties: In feedback to the Commission in 2020, both Crédit Agricole and Amundi appeared to support for the consideration of adverse impacts on sustainability within fiduciary duty, but only where there is a clear mandate from the asset owner to do so. However, Amundi argued against the prescriptiveness of the proposed Sustainable Finance Disclosure Regulation (SFDR) in comments to the European Supervisory Authorities’ (ESAs) consultation in 2020.

Lobbying Transparency: At the group level, Crédit Agricole has disclosed some general positions on its website, but has not referenced specific policies or described engagement activities. Amundi discloses some of the sustainable finance policies it is tracking with some details of engagement, but did not describe positions taken. Amundi has listed its trade association memberships but has not clearly described the management of its indirect influence. There does not appear to be group level disclosure of indirect sustainable finance policy engagement, although Crédit Agricole has disclosed corporate membership of the board in its financial reporting.