We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
Sustainable Finance Lobbying Overview: European Association of Co-operative Banks (EACB) appears to have engaged against stringent regulatory interventions on sustainable finance policy in Europe.
Top-line Messaging on Sustainable Finance Policy: EACB has stated support for the role of the finance industry in meeting the Paris Agreement and the European Green Deal and achieving net-zero by 2050.t However, it has not clearly articulated a position on the need for systemic reform to achieve a sustainable financial system. EACB has argued that regulation in this area must be “workable” and “proportionate”, and has particularly emphasized that regulation should occur at the level of the real economy.
Position on Regulated Corporate ESG Disclosure: EACB appears to be supportive of improved corporate ESG disclosure requirements. In the 2020 European Commission consultation on the review of the NFRD, EACB appeared to be more supportive of improving regulated corporate ESG disclosure. EACB also appeared supportive of the subsequent proposal for a Corporate Sustainability Reporting Directive (CSRD) in a Commission consultation in 2021, suggesting in a position paper that disclosure requirements in the CSRD should be adapted to SMEs. However, in response to EFRAG’s consultation on the draft European Sustainability Reporting Standards (ESRS), EACB argued that the disclosure requirements are too complex and challenging to implement in the legislation timeline and suggested considering the cost/benefit balance of some of the standards.
Position on Taxonomies: During 2019, EACB raised several concerns on the EU taxonomy, suggesting that the framework was too complex and supporting the weakening of some of the thresholds on what would constitute a ‘green’ investment. In feedback to the European Commission's consultation on the Renewed Sustainable Finance Strategy in 2020, EACB supported a weakening of the current transitional category and opposed expansion to cover environmentally harmful activities. However, in feedback to the EU’s Platform on Sustainable Finance in 2021, EACB appeared to support the creation of a “social” taxonomy and took a mixed position on the expansion to harmful activities. In a 2021 policy position and annual report, EACB further supported a taxonomy covering transition activities, but emphasized that the framework needs to be based on a “dynamic and positive” formula that encourages the transition. It also [871136 reinforced these points on a call for action during COP26.
Position on ESG Standards, Labels & Benchmarks: In 2019, EACB's feedback to the Technical Expert Group (TEG) on the creation of an EU Green Bond Standard suggested support for a stringent standard, including alignment with the taxonomy and stringent requirements for reporting and external review. It also supported verification requirements for the EU GBS in feedback to the Commission in 2020. However, in feedback to the JRC on the creation of an EU Ecolabel for retail financial products in 2020, EACB supported the EU Ecolabel with a number of exceptions including arguing for some criteria to be weakened and suggesting that some of the compliance and verification requirements were too onerous.
Position on Integrating ESG into Investor Duties: In feedback to the Commission in 2020, EACB opposed updating fiduciary duty to include ESG issues and further opposed updating MiFID II to include ESG considerations into the advice given to clients. In response to the ESA’s Sustainable Finance Disclosure Regulation (SFDR) consultation on investor ESG disclosure in 2020, EACB argued against the stringency of the regulation and asked for considerations of the incurred costs to investors.
Lobbying Transparency: EACB is fully transparent about its sustainable finance positions, including detail of engagement activities. It is also transparent about its members, including which companies and individuals hold key positions in the executive and on key committees.