ICICI Lombard General Insurance Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	ICICI Lombard General Insurance Co Ltd demonstrates robust internal oversight for investment stewardship and ESG risk, but it does not disclose any governance structures specifically for lobbying activities or climate-related advocacy. The company mandates that “a summary of resolutions voted in favor or against or abstained from voting be reported to the Investment Committee and the Audit Committee for its review on a quarterly basis,” and stipulates that “the Company shall comply with all the principles given in the guidelines and submit an Annual Certificate of Compliance approved by the Board … duly certified by the CEO and the Compliance Officer on or before June 30th every year.” Stewardship oversight is formalized through the “Board Investment Committee,” supported by the “Local Management Investment Committee” under its supervision, and voting activities are monitored by the Audit Committee reporting to the Board. Additionally, “effective oversight over ESG is to be handled by the CSR & Sustainability Board Committee,” and ESG Risk is governed under its Board Approved Risk Management Framework with “Quarterly updates on ESG Risk Management … presented to the Risk Management Committee of the Board.” We found no evidence of any policy or process governing the alignment of direct or indirect lobbying with corporate climate or policy positions. View Sources	E

Overall Assessment

Analysis

Score

None

ICICI Lombard General Insurance Co Ltd demonstrates robust internal oversight for investment stewardship and ESG risk, but it does not disclose any governance structures specifically for lobbying activities or climate-related advocacy. The company mandates that “a summary of resolutions voted in favor or against or abstained from voting be reported to the Investment Committee and the Audit Committee for its review on a quarterly basis,” and stipulates that “the Company shall comply with all the principles given in the guidelines and submit an Annual Certificate of Compliance approved by the Board … duly certified by the CEO and the Compliance Officer on or before June 30th every year.” Stewardship oversight is formalized through the “Board Investment Committee,” supported by the “Local Management Investment Committee” under its supervision, and voting activities are monitored by the Audit Committee reporting to the Board. Additionally, “effective oversight over ESG is to be handled by the CSR & Sustainability Board Committee,” and ESG Risk is governed under its Board Approved Risk Management Framework with “Quarterly updates on ESG Risk Management … presented to the Risk Management Committee of the Board.” We found no evidence of any policy or process governing the alignment of direct or indirect lobbying with corporate climate or policy positions.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	ICICI Lombard General Insurance Co. Ltd. offers only limited visibility into its climate-related lobbying. It notes that it participates in public-policy advocacy through trade bodies such as the Indian Merchants Chamber, Confederation of Indian Industry and Federation of Indian Chambers of Commerce and Industry, indicating that it uses industry associations as an indirect channel of engagement. Beyond naming these affiliations, however, the company does not describe how it lobbies—no letters, meetings, consultations or other methods—and it does not identify any specific government departments or policymakers it addresses. Crucially, the disclosure mentions no climate-related laws, regulations or policy proposals on which the company has taken a position, nor does it set out the policy changes or outcomes it hopes to achieve. As a result, the information released conveys only that the company is active in general policy advocacy through trade associations, without clarifying the climate focus, the method of influence, or the objectives sought.	D