Aavas Financiers Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Aavas Financiers Limited is reasonably clear that it does not undertake climate-related lobbying. It states, "The Company does not take part in any lobbying and has not propagated any public policy positions," thereby being transparent about its lack of direct engagement with legislation or regulation. The disclosure notes that any advocacy it does undertake is channeled through bodies such as the PHD Chamber of Commerce and Industry and through participation in IFC-hosted webinars, but it stops short of describing these activities as lobbying and does not name any specific climate or sustainability policies it has tried to influence. By openly declaring non-engagement, the company provides a fair level of clarity on both the policies lobbied and the mechanisms used, although it does not offer a detailed rationale for this stance. Because it reports no lobbying, it understandably cites no concrete policy changes or legislative outcomes it is seeking, leaving its policy objectives only broadly characterised as support for “financial inclusion, green construction and sustainable housing.” Overall, the disclosures give a moderately detailed picture of the company’s absence of climate-policy lobbying, but provide limited insight into the reasons behind that position or any desired policy outcomes.	2

Lobbying Governance

Overall Assessment	Comment	Score
None	Aavas Financiers has established a detailed multi-tier ESG governance structure—“To uphold this philosophy, the Board of Aavas has determined that the CSR & ESG Committee will have oversight on ESG matters within the Company,” supported by “a management-level ESG Steering Committee” and “three area specific working groups”—but it does not disclose any specific governance process for its lobbying activities. Although the Company notes it is a member of the “PHD Chamber of Commerce and Industry (PHD Chamber)” and that “The Company’s leadership … puts forth a number of suggestions and ideas … such as financial inclusion of women, green construction, sustainable housing,” there is no description of who oversees or reviews these lobbying efforts, how they are monitored or managed, or any policy to ensure alignment of its advocacy with the Company’s broader objectives, nor is a dedicated individual or formal body assigned to govern lobbying engagements.	0