360 ONE WAM Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
None No evidence found 0
Lobbying Governance
Overall Assessment Comment Score
None 360 ONE WAM Ltd’s disclosures focus exclusively on its stewardship code for investment activities, with the Code’s approval by “the Board of Directors of 360 ONE AAM and 360 ONE Asset Trustee Limited (formerly known as IIFL Trustee Limited) (Trustee to 360 ONE AIFs)” and the involvement of its “Chief Investment Officer and Fund Manager(s) of concerning Scheme(s)” in implementation of the Stewardship Code. The escalation matrix outlines steps from “Communication: The Investment Manager shall communicate to the investee company’s management about any concerns” through “Engagement,” “Collaboration,” “Escalation,” and “Reporting to the Regulators.” However, we found no evidence of any governance process for overseeing or aligning the company’s direct or indirect lobbying activities—there is no mention of policies, monitoring procedures, responsible individuals, oversight bodies, or alignment of lobbying with climate or other policy goals. This indicates that while the company has robust stewardship procedures for investee engagement, it does not disclose any mechanism for governing lobbying. 0