Bank of India – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Bank of India discloses a general framework that covers how it approaches policy advocacy within its wider Business Responsibility and Sustainability (BRS) programme, indicating a moderate level of lobbying governance. It states that “The Bank, while pursuing policy advocacy, will ensure that the advocacy positions are consistent with the Principles and Core Elements contained in National Voluntary Guidelines,” signalling an explicit commitment to align any lobbying positions with predefined sustainability principles. Oversight responsibilities are clearly assigned: “The Board of Directors retain ultimate responsibility for the Bank’s Business Responsibility and Sustainability … and thereby have the overseeing responsibility for the management of the Bank’s BRS,” and a dedicated “Business Responsibility and Sustainability Sub Committee” is charged with reviewing disclosures before publication. Day-to-day implementation is delegated to a named official, as “The designated Nodal Officer of the Bank shall have a direct reporting line to Managing Director & CEO and Executive Directors and be responsible for ensuring effective implementation of the BRS policy.” While these disclosures identify a policy alignment requirement, specify senior oversight bodies, and name an accountable officer, the company does not disclose a detailed process for monitoring or auditing lobbying activities, provides no climate-specific alignment criteria, and offers no evidence of reviewing or managing positions taken by trade associations, which limits transparency on how alignment is enforced in practice. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Bank of India discloses a general framework that covers how it approaches policy advocacy within its wider Business Responsibility and Sustainability (BRS) programme, indicating a moderate level of lobbying governance. It states that “The Bank, while pursuing policy advocacy, will ensure that the advocacy positions are consistent with the Principles and Core Elements contained in National Voluntary Guidelines,” signalling an explicit commitment to align any lobbying positions with predefined sustainability principles. Oversight responsibilities are clearly assigned: “The Board of Directors retain ultimate responsibility for the Bank’s Business Responsibility and Sustainability … and thereby have the overseeing responsibility for the management of the Bank’s BRS,” and a dedicated “Business Responsibility and Sustainability Sub Committee” is charged with reviewing disclosures before publication. Day-to-day implementation is delegated to a named official, as “The designated Nodal Officer of the Bank shall have a direct reporting line to Managing Director & CEO and Executive Directors and be responsible for ensuring effective implementation of the BRS policy.” While these disclosures identify a policy alignment requirement, specify senior oversight bodies, and name an accountable officer, the company does not disclose a detailed process for monitoring or auditing lobbying activities, provides no climate-specific alignment criteria, and offers no evidence of reviewing or managing positions taken by trade associations, which limits transparency on how alignment is enforced in practice.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Bank of India provides only minimal insight into its climate-related lobbying. The bank notes that it channels any engagement through trade and industry associations, which at least identifies an indirect mechanism, but it does not say whether this involves meetings, written submissions, or other tools, nor does it name the government bodies or jurisdictions approached. It offers no detail on the specific climate policies, laws, or regulations it has sought to influence, and it is silent on the concrete policy positions or outcomes it hopes to achieve. As a result, stakeholders cannot determine either the scope or the intent of the bank’s climate-policy advocacy.	D