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NATIXIS

Natixis is the international corporate and investment banking, wealth & asset management, insurance and payment arm of Group BPCE, the second-largest banking group in France.

Lobbying Activity

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and MIROVA

2 Feb 2023 · SFDR

Meeting with Gert Jan Koopman (Director-General Budget)

4 Feb 2022 · NGEU

Meeting with Gert Jan Koopman (Director-General Budget)

14 Oct 2021 · Next Generation EU

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and BNP PARIBAS and

29 Sept 2021 · MiFID/MiFIR

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association for Financial Markets in Europe and

27 Apr 2021 · Sustainable Finance

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and BNP PARIBAS and

27 Apr 2021 · MiFIR, EU/UK regulatory and Secondary market liquidity

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and

9 Mar 2021 · Basel III

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and

10 Feb 2021 · Basel III

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and FTI Consulting Belgium

21 Jan 2021 · regulatory cooperation EU-US

Meeting with Kadri Simson (Commissioner) and

10 Jul 2020 · Exchange of views on energy system integration and hydrogen strategies.

Response to References to ESG factors enabling market participants to make well-informed choices

6 May 2020

The draft delegated act on the benchmark statement could prevent the market for ESG-related benchmark to develop if further specification and some amendments are not taken into consideration by the European Commission: • First, we note that the draft delegated act published by the Commission does not take into account the requirement made by the level 1 text that the ESG information should be reflected in each benchmark or family of benchmark: this change in the requirement questions the principle of family of benchmark by demanding that a benchmark statement should be established for each benchmark, which clearly contradicts the Benchmark Regulation. Therefore the Commission should align the provisions of Article 2(1) of the Delegated Act on Article 27(2a) of the Benchmark Regulation. • Second, while we acknowledge that it is important for an ESG-related benchmark to disclose information relating to all three pillars (E, S and G), some of the proposed environmental factors are over-ambitious and cannot be disclosed considering the lack of data availability as of today. The question of data availability being at the center of this Regulation, it is important that it is available and accessible at a reasonable cost to benchmark administrators for the market to gain momentum. Our analysis shows that the 3 following factors are not yet available and hence could not be disclosed as of today: o Exposure of the benchmark portfolio to renewable energy as measured by capital expenditures (CapEx) in those activities (as a share of total CapEx by energy companies included in the portfolio); o Exposure of the benchmark portfolio to climate-related physical risks, measuring the effects of extreme weather events on companies’ operations and production or on the different stages of the supply chain (based on issuer exposure); o Degree of exposure of the portfolio to climate-related opportunities, measuring investment opportunities related to climate change, innovating new investment solutions, as percentage of total weight in portfolio. We would hence suggest that those 3 factors are made voluntary at this stage, with the medium/long term objective to make them mandatory once the data availability has improved. For the other factors, our analysis shows that the data is generally available. Furthermore, the delegated act requires benchmark administrators to communicate on the data source of the ESG information published: it is important to point out that benchmark administrators often use external data providers. They hence cannot be made responsible for the data quality control of the data sourced externally. As for all legislation regarding sustainable finance, the issue of data availability remains. We would also like to specify that financial institutions being intermediaries, they cannot be held accountable for disclosing data that their clients are not themselves entitled to disclose. • Finally, some operational modalities need further specification from the European Commission: it is in particular the case for the provisions regarding the update of the ESG information included in the benchmark statement. We understand that the common rules established in article 27(1) of BMR and article 6 of the Delegated Regulation (EU) 2018/1643 of 13 July 2018 should apply. However, for more clarity, the Commission should specify it in the Delegated Act.
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Response to Minimum standards for benchmarks labelled as EU Climate Transition and EU Paris-aligned Benchmarks

6 May 2020

Overall, the criteria proposed are sound. We would however like to highlight the following comments to the Commission: • We believe that there is not enough differentiation in terms of stringency between the CTB and PAB, which will prevent the market to gain momentum. Regarding the decarbonization trajectory, we believe it is too stringent for CTBs and that constraints should be eased: we would suggest including in the trajectory forward looking considerations for CTBs. It should also be considered over a 5-year period rather than annually. • Regarding the definition of greenhouse gas (GHG) intensity, we note that the Commission chose to divide absolute GHG emissions by millions of Euros in enterprise value including cash. This methodology has the disadvantage of creating an artificial bias that will make the GHG intensity fluctuate depending on the market conditions (if enterprise is in difficulty, the GHG intensity will artificially rise, while it might have no impact on the environment). One possible way to mitigate this bias is to use the enterprise revenues as denominator: economically speaking, the more a company produces, the more its environmental impact should be important. It should also be noted that the indicator is not flawless either. • The scope 3 phase-in should be deleted in order to avoid undesirable effects on the operational management of the benchmark for each different phase: it will introduce bias in the benchmark methodology and will create major variations in the benchmark composition during the first 5 years. Scope 3 should hence be included for all sectors as soon as the Regulation enters into force. • We regret that the TEG recommendation on the “do no significant harm” principle for CTBs (companies involved in any activities related to controversial weapons; companies involved in any activities related to tobacco; companies that benchmark administrators find in violation of the UNGC principles or the OECD Guidelines for Multinational Enterprises) were not kept by the Commission. Furthermore, we believe it is of the utmost importance to include sovereign indices in the scope of climate-related benchmarks in order to enhance the transition. The notion of alignment makes even more sense for sovereigns than for corporate issuers, although the criteria to be used are different (assessment of the NDCs temperature alignment are available: Climate change performance Index and Climate Transparency). As an example, for criteria, in the SDSN/Bertelsmann Report, Goal 13 (Climate Action) is measured using 4 indicators: Energy-related CO2 emissions per capita; Imported CO2 emissions, technology adjusted; people affected by climate disasters and C02 emissions embodied in fossil fuel exports.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Nathalie De Basaldua Lemarchand (Cabinet of Vice-President Jyrki Katainen)

8 Nov 2018 · EU financial services proposals, currently being negotiated, which affect the asset management business globally.