Sustainable Finance Lobbying Overview: UBS appears to be engaged in the EU on sustainable finance policy, while not supporting stringent regulatory intervention.

Top-line Messaging on Sustainable Finance Policy: UBS has communicated support for keeping the global temperature rise to below 1.5 degrees and in a 2021 whitepaper, it supported action to achieve net-zero by 2050. In 2020 as well as 2021 and 2022. UBS Asset Management also co-signed investor letters to EU leaders and governments, respectively, advocating for action to achieve net-zero by 2050. In a joint statement in 2022, it also advocated for the post-2020 global biodiversity framework to mandate the alignment of financial flows with biodiversity goals. However, in prior messaging, UBS appeared to have supported measures that seemingly contradict this goal. For example, in a 2019 whitepaper the group appears to have stated support for the continued role for GHG emission intense investments and CEO Sergio Ermotti reportedly arguing against "moving too quickly". More recently, UBS showed continued support for continued investment in fossil fuels in a letter submitted to the Municipal Advisory Council of Texas in 2022. UBS Asset Management appears to be cautious about stringent, science-based regulatory intervention on sustainable finance, emphasizing in a 2019 whitepaper that the EU's Sustainable Finance Action Plan "must serve investors’ needs" and be “compatible with clients’ investment objectives”. Similarly, in a 2021 whitepaper, UBS acknowledged the risk of sustainable finance regulation but has not stated a clear position.

Position on Regulated Corporate ESG Disclosure: In its 2019-22 CDP responses, UBS advocated for the implementation of the TCFD's recommendations into disclosure frameworks, particularly in Switzerland. Alex Weber, chairman of UBS bank, also appeared to support a regulatory European approach to sustainability disclosures in a 2021 media article. UBS also offered support for ambitious global sustainability standards in response to the International Sustainability Standards Board (ISSB) in 2021. In an investor statement on 2022, UBS Asset Management supported the implementation of the TCFD and 1.5 pathway-aligned transition plans. Post COP15, UBS Asset Management advocated for policymakers to support the assessment and disclosure of nature-related impacts and dependencies in a joint investor statement in 2022, and it has further supported the alignment of disclosures with the TNFD in a 2023 website article.

Position on Taxonomies: UBS Asset Management appears to support a less stringent approach to the EU's taxonomy, raising concerns in a 2019 whitepaper that the taxonomy was too narrow and possibly supporting the inclusion of certain oil and gas activities in a green taxonomy. Similarly, Huw was Steenis, chair of sustainable finance at UBS, argued in a 2021 Washington Post article that the taxonomy may be too binary. In a 2022 Financial Times article, a strategist at UBS supported the inclusion of gas and nuclear in the EU Taxonomy, arguing that “encouraging the use of the cleanest fossil fuels, like natural gas, over the dirtiest, such as coal, is an important step”.

Position on ESG Standards, Labels & Benchmarks: In a 2019 whitepaper, UBS Asset Management supported EU’s climate benchmarks but cautioned against stringent criteria that would overly restrict the investment universe. UBS has also offered broad high-level support for the EU Green Bond Standard in website articles in 2020 and 2022.

Position on Integrating ESG into Stress Testing and into Investor Duties: In its 2021 CDP response, UBS appeared to support the integration of ESG factor into stress testing. However, in a 2021 whitepaper, it cautioned that models are in early phases and that differing standards, data taxonomies and scenarios will make interpretation more difficult for investors. UBS Asset Management did appear to support the EU’s Sustainable Finance Disclosure Regulation (SFDR) in a website article in 2021.

Lobbying Transparency: At the group level, UBS has described some broad policy positions in various whitepapers, while UBS Asset Management has listed policy positions and consultations it has engaged with in a whitepaper and in its stewardship reports. UBS has also disclosed some of its sustainability-related memberships in its sustainability report, but key indirect influence details, such as AFME board membership, are missing. UBS Asset management has disclosed some memberships to industry groups and some activities related to these groups, but has not given details on the sustainable finance policy positions of these organizations.