Sustainable Finance Lobbying Overview: Groupe BPCE appears to have mixed positions on sustainable finance, with most of this engagement concentrated with two subsidiaries, Natixis and Mirova. Mirova shows particularly positive engagement with sustainable finance policy.

Top-line Messaging on Sustainable Finance Policy: Mirova has consistently stated support for systemic reform to achieve a sustainable finance system and has advocated for action to achieve zero-carbon economies by 2050. Natixis has also supported action to achieve net-zero economies and to keep global temperature rise to 1.5. In 2022, Mirova advocated for the post-2020 global biodiversity framework to mandate the alignment of financial flows with biodiversity goals. Mirova has also supported ambitious regulation on sustainable finance, including the EU's Action Plan, and supported increased ambition on policy actions to accelerate the systemic sustainability transition. Mirova CEO Philippe Zaouati has highlighted that current sustainable finance policies lead to more disclosure, but do not necessarily lead to action on this information.

Position on Regulated Corporate ESG Disclosure: Groupe BPCE and subsidiaries have been particularly engaged on regulated corporate ESG disclosure, with specific positive engagement from Mirova. Natixis and Mirova have offered broad support for regulated corporate ESG disclosure, including the SEC climate disclosures and the European Sustainability Requirement Standards (ESRS) in website articles and reports during 2021-2022. Natixis has also supported the “double materiality” approach. However, in response to UK Department for Work and Pensions (DWP) in 2020, Natixis Investment Managers suggested a delayed implementation of TCFD-aligned disclosures for occupational pension schemes and argued against mandating specific metric and targets. In a similar consultation in 2021, it restated these same concerns. In response to the 2022 SEC consultation, Mirova strongly supported the proposed climate disclosure rule and advocated for increased ambition, such as the inclusion of the double materiality approach. In response to the European Commission in 2022, Groupe BPCE argued that the ESRS disclosure standards are "extremely numerous, granular and very time-consuming" and advised against a number of the proposed social standard disclosures. In a joint statement in 2022, Mirova advocated for policymakers to support the assessment and disclosure of nature-related impacts and dependencies

Position on Taxonomies: During 2021, Mirova, and particularly Mirova’s CEO, was highly supportive of the taxonomy in social media, consistently warning against lowering its ambition. In a letter to the Commission co-signed by Manues Coeslier from Mirova, it also advocated further advised against the inclusion of natural gas in the taxonomy. This position was reinforced by Mirova in its sustainability report and in the media. Natixis has also supported the policy on its website, in consultations and in media interviews, including clear support for rigorous science-based criteria and support for the expansion of the taxonomy to cover environmentally harmful activities. However, in a dedicated report on the taxonomy, Natixis appeared to advocate for broadening of the transition definition, which could lead to a less stringent classification system and Groupe BPCE cautioned against the “binary nature” of the taxonomy in a website article in 2022.

Position on ESG Labels: Mirova stated active support for the EU Ecolabel in a 2019 newsletter, and reiterated its support for an "ambitious" label in a 2019 ESMA consultation and in a website article in 2021. However, in a 2021 website article and report, it did argue that the thresholds for the Ecolabel should be realistic and that in its current status it would not add value. In response to the Commission in 2020, Mirova also supported a number of ESG labels suggested by the Commission (e.g. ESG investment fund, broader ESG benchmarks). In a website article in 2022, Natixis also offered broad support for the US SEC’s “Names Rule” to tackle misleading labelling of funds.

Position on ESG Benchmarks: In 2019-2020 Mirova stated support for the EU's climate benchmarks and ESG disclosure on all benchmarks on social media, although in a 2019 dedicated report, it did state that the usability and scalability of EU Climate Benchmarks depended on the balance “between ambition and pragmatism”. However, in feedback to the European Commission on the benchmarks regulation in 2020, Natixis expressed concern at the lack of differentiation of stringency between the two proposed categories of benchmark and suggested that data availability was a concern for some of the proposed ESG disclosures. In a 2021 website article, Natixis Investment Managers also stated that it was not the time for regulation on ESG standards, labels and benchmarks given ESG has not yet been defined.

Position on ESG Standards: Natixis suggested that the thresholds for the EU Green Bond Standard should not be too stringent to avoid reducing uptake in feedback to the European Commission's Technical Expert Group (TEG) in 2019 and on its website in 2020. In response to the Commission in 2020, Mirova supported the verification of the EU Green Bond Standard. In a 2021 website article, Natixis stated concerns around a number of EU GBS requirements and opposed the need for it to be mandatory. In 2022, it also highlighted a number of exceptions to the EU Parliament’s suggestions and supported the Council’s approach to create flexibility to the standard as to “ease ... adoption ... without watering it down too much”.

Position on Integrating ESG into Investor Duties: In 2019, Mirova appeared to be actively supporting incorporating ESG factors into fiduciary duty and has strongly supported related policies including the investors' disclosures regulation, on social media and in interviews, and the integration of ESG preferences in the advice investment firms give to clients, in consultation responses. In 2020, Natixis also opposed the US Department of Labor's rollback which limited fiduciaries' ESG investing and Natixis Investment Mangers advocated in a 2021 website article for the US Department of Labor to increase its ambition in the integration of ESG into fiduciary duties. However, in response to the Department of Labor in 2021, Natixis Investment Managers argued for weakening the language relating to ESG considerations by plan investment fiduciaries. Mirova appeared to support the EU’s Sustainable Finance Disclosure Regulation (SFDR) in 2021-2022 website articles and newsletter. However, Natixis Investment Managers did argue that the SFDR text could be confusing and be interpreted in different ways. In a website article in 2022, Natixis also offered broad support for the SEC’s proposed rule to enhance specific ESG disclosures from funds and advisers.

Position on the integration of ESG factors into prudential regulation:Natixis appeared to support the inclusion of ESG factors into prudential regulation in a 2020 website article.

Lobbying Transparency: At the group level, Groupe BPCE does not appear to disclose any positions on sustainable finance policies. Subsidiary Mirova has a clear disclosure of its sustainable finance policy engagement in its Engagement Reports. Natixis and Natixis Investment Managers do disclose some positions in website articles, but no dedicated disclosure. Groupe BPCE has disclosed some information on engagements with trade associations, but lacks a dedicated disclosure or further details on indirect influence. Mirova has listed its trade association's memberships and sustainable finance policy positions in broad terms, but has not referenced specific policies. There does not appear to be any disclosure on this from the rest of the financial group.