Commerzbank 

The financial institution has publicly available policy statements committing to respect ILO core labour rights and expecting suppliers to do the same. It discloses quantitative information on worker health and safety, identifies bribery and corruption risks, and outlines its approach to lobbying and political engagement, specifying that it does not make political contributions and disclosing lobbying expenditures.

In terms of governance, decision-making and oversight for the sustainability strategy are assigned to the highest governance body, with performance criteria for senior executive remuneration linked to sustainability targets. Furthermore, responsibility for implementing the sustainability strategy is also delegated to specific functions, teams, or committees.

The financial institution also has a policy statement committing to respect human rights and discloses a list of trade associations it is a member of. It transparently identifies nature-related impacts associated with its products, services, and capital, prioritizing sectors with the highest impact. Additionally, it monitors scope 1-2 emissions and some scope 3 emissions categories. Finally, it discloses operational data by country, such as employee numbers or revenue.

The institution has the opportunity to disclose its methodology for determining a living wage in its operational regions. It identifies material sustainability impacts across its value chain but could provide more detail on the objective criteria and evidence used for prioritisation. Although third-party assurance has been performed, it is unclear if the targets are included.

While the financial institution has exclusion criteria for certain fossil fuel projects, a universal ban on all current and new fossil fuel projects could be implemented. Although the entity monitors scope 3 emissions beyond financed emissions, additional categories could be included with justifications for those excluded. The methodology for calculating the carbon footprint is disclosed, but data sources and conversion factors, as well as additional Scope 3 categories, should be included in future.

Additional recommendations include disclosing a transition plan for operations, supply chain, and portfolio, as well as ensuring scope 1-3 emissions reduce in line with interim targets. It is also advised to disclose processes to prevent divestment from low-income countries due to sustainability strategies, include risks related to ILO fundamental rights of work in risk assessments, and establish mitigation processes for identified risks. Furthermore, the institution should identify social risks linked to its products and provide examples of actions taken regarding salient human rights issues from assessments conducted in the last three years. Finally, the entity should disclose a breakdown of its clients by income group.

This scorecard refers to information in English which was publicly available by July 15 2024. AuM and Total assets are stated in USD for comparability and have been calculated based on reported local currency values multiplied by applicable IMF currency converter values.