Sustainable Finance Lobbying Overview: HSBC appears to be actively engaging on sustainable finance policy, with mixed positions.

Top-line Messaging on Sustainable Finance Policy: HSBC has consistently stated support for a role for finance in meeting the goals of the Paris Agreement, and appears to support reform to address short-termism in markets. More recently, HSBC and HSBC Global Asset Management advocated for action to achieve net-zero by 2050. In 2021 and 2022, HSBC Global Asset Management also participated in joint investor statements to governments advocating for net-zero by 2050. However, in a 2022 conference, HSBC chief executive Noel Quinn criticized climate protests and argued that transition to net-zero would be hampered if banks pulled financing to oil and gas companies. HSBC has stated broad support for regulation on sustainable finance on its website and CDP response but has appeared more cautious in its consultation responses to policymakers. Messaging from HSBC Global Asset Management appears to be more supportive of policy on sustainable finance than positions at the group level.

Position on Regulated Corporate ESG Disclosure: HSBC has been strongly supportive of improving regulated corporate ESG disclosure on its website in 2022, and mandatory TCFD reporting in a consultation response to the Commission in 2020. HSBC Global Asset Management has also advocated for mandatory implementation of the TCFD and 1.5 pathway-aligned transition plans in a joint investor statement in 2022. In response to the UK’s Financial Conduct Authority (FCA) in 2020, HSBC supported regulatory implementation of the TCFD for listed issuers and suggested greater ambition. HSBC restated this position in responses to the House of Commons’ Inquiry into decarbonization of the UK economy. However, in two Department of Work and Pensions (DWP) consultation in 2020 and 2021, subsidiary HSBC Bank Pension Trust (UK) proposed a delay to TCFD reporting requirements for occupational pension schemes. HSBC offered broad support to the ISSB Sustainability and Climate Disclosure Exposure Drafts, which are likely to inform government policy, while HSBC Bank Pension Scheme advocated for increased ambition, including a double materiality lens.

Position on Taxonomies: HSBC Global Asset Management stated support for the EU's taxonomy in its 2019 Responsible Investment Review. However, at a group level, in feedback to the European Commission's Technical Expert Group (TEG) in 2019, HSBC appeared to argue for a less rigorous process for classification based on market-set standards rather than scientifically determined thresholds. In response to the Commission in 2020, HSBC did not appear to support the extension of the taxonomy to cover environmentally harmful activities. In a 2022 report, HSBC supported the need for a social taxonomy in the EU.

Position on ESG Standards, Labels & Benchmarks: HSBC Global Asset Management also stated high-level support for the EU Green Bond Standard in its 2020 Responsible Investment Review. However, at a group level, HSBC was less positive in its feedback to the TEG in 2019, suggesting that high standards should be balanced against not constraining "market development" and suggesting a less rigorous accreditation scheme. It also suggested additional criteria and thresholds should be clarified for non-EU issuers in response to the European Commission in 2020.

Position on Integrating ESG into Investor Duties: Similarly, despite HSBC Global Asset Management stating high-level support for the inclusion of ESG issues in fiduciary duty, in a 2019 ESMA consultation HSBC supported related policy to integrate ESG considerations into client advice but argued it should be introduced gradually and that advisors should be able to consider non-ESG products in suitability assessments for clients who have expressed preferences for ESG products. On its 2021 Responsible Investment Review, HSBC Global Asset Management supported the EU’s disclosures regulation (SFDR).

Position on Incorporating ESG factors into Risk Management and Prudential Regulation: In response to the Commission in 2020 and CDP in 2020-2021, HSBC supported the inclusion of ESG factors in prudential regulation and incorporating ESG factors into risk management, respectively.

Lobbying Transparency: HSBC Global Asset Management has a disclosure of its public policy advocacy with some details of positions taken, but there does not appear to be group-level disclosure. HSBC has disclosed its trade association memberships but has not given any further details of its governance of indirect influence. At the subsidiary-level, HSBC Global Asset Management has also disclosed some of its association memberships, but no other details around indirect influence.