Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
Norges Bank Investment Management is the investment management division of the Norwegian Central Bank (Norges Bank) and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with 12,429 billion Norwegian kroner, or around 1,186 billion EUR, at year end 2022.
Deutsches Aktieninstitut has followed the debate ahead of the proposal very closely from the perspective of German listed companies. It is well known that as a consequence of investors interests and needs, ESG factors and ESG ratings have become increasingly relevant for access to finance and costs of finance of companies in Europe.
We are referring to the European Commissions proposal for a Directive on multiple-vote share structures in companies that seek admission to trading on an SME growth market, published in December 2022, and the related feedback period. We appreciate the opportunity to contribute our views on this legislative proposal.
Deutsches Aktieninstitut welcomes the draft of the EU Listing Act of December 7th, 2022. We support the European Commission in its intention to reduce the bureaucratic burden, improve legal certainty and reach real improvement for the practice of listed companies. This objective is fully shared by us.
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