Aditya Birla Sun Life Asset Management Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Aditya Birla Sun Life Asset Management Co Ltd’s disclosures centre entirely on its stewardship policy for investee companies, including an annual review that “will be reviewed and updated once every year and will be disclosed on the website of ABSLAMC” and escalation procedures where issues “will be discussed at the Investment Committee of ABSLAMC for further escalation to the Board of Directors of the investee company,” but we found no evidence of any internal processes, oversight structures, or accountability measures governing the company’s political lobbying activities. The policy details how “the Investment team will be accountable for monitoring all the companies in which ABSLAMC invests” and that “Effective oversight on the stewardship activities is to be reviewed by Board for compliance,” yet the company does not disclose any mechanism to ensure alignment of direct or indirect lobbying with its climate or policy positions, nor does it name any individual or committee responsible for overseeing lobbying alignment. View Sources	E

Overall Assessment

Analysis

Score

None

Aditya Birla Sun Life Asset Management Co Ltd’s disclosures centre entirely on its stewardship policy for investee companies, including an annual review that “will be reviewed and updated once every year and will be disclosed on the website of ABSLAMC” and escalation procedures where issues “will be discussed at the Investment Committee of ABSLAMC for further escalation to the Board of Directors of the investee company,” but we found no evidence of any internal processes, oversight structures, or accountability measures governing the company’s political lobbying activities. The policy details how “the Investment team will be accountable for monitoring all the companies in which ABSLAMC invests” and that “Effective oversight on the stewardship activities is to be reviewed by Board for compliance,” yet the company does not disclose any mechanism to ensure alignment of direct or indirect lobbying with its climate or policy positions, nor does it name any individual or committee responsible for overseeing lobbying alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E