Commerzbank

In terms of senior leadership accountability, Commerzbank links the remuneration of its executive team to sustainability performance criteria. The responsibility for sustainability issues within the bank lies with its highest governing body. Moreover, Commerzbank has a gender-balanced board of directors where 9 out of 20 members are women. Regarding its approach towards impact management, the bank acknowledges that its financing activities have both positive and negative impacts. Commerzbank also discloses a list of trade associations of which it is a member including sustainability- and non-sustainability-related organisations.

Commerzbank has set a target of net-zero financed emissions by 2050. It is also committed to minimising its negative impacts on nature and biodiversity.

Commerzbank has publicly available policy statements committing it to respect human rights and the health and safety of workers. It also has a grievance mechanism accessible to all workers, external individuals and communities to raise human rights complaints or bribery and corruption concerns. Moreover, the bank has a policy prohibiting bribery and corruption and takes steps to identify and address them. Commerzbank discloses that an executive-level individual has responsibility for its global tax strategy and discloses income tax payments for all its tax jurisdictions. In a public policy statement, Commerzbank discloses its approach to lobbying and political engagement. The bank specifies that it does not make political contributions.

Commerzbank has an opportunity to describe its engagement approach on sustainability themes and impact topics with clients and investees. In terms of gender equality, the bank has an opportunity to reach at least 40% female representation in senior leadership positions. Moreover, there is no evidence that Commerzbank discloses the ratio of basic salary and remuneration of women to men in its total direct operations workforce for each employee category.

Commerzbank could disclose interim emissions reduction targets at the group level, such as a 45% reduction in financed emissions by 2030. It also has an opportunity to disclose the key sectors and companies it has identified as priorities to engage with on climate change, specifically on the alignment with the Paris Agreement. Furthermore, there is no evidence that the bank discloses its financing activities devoted to climate solutions. No evidence was found regarding the Commerzbank’s approach to fossil fuels that spans across the fossil fuel value chain and its financing activities, such as the amount or share of finance it directs towards fuels, or its stance on financing companies with new fossil fuel projects.

There is no evidence that Commerzbank describes the process for identifying its human rights risks and impacts through its relevant financing activities. While the bank discloses the ages of its Board of Managing Directors, its Supervisory Board, and German workforce, it has an opportunity to disclose this information for each employee category. To provide transparency on financial inclusivity, Commerzbank has an opportunity to disclose the amount of finance directed towards, for example, women-owned businesses, small- and medium-sized enterprises (SMEs) or low-income developing countries.