ICICI Bank Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	ICICI Bank provides a moderate level of transparency about its climate-related lobbying. It names two concrete policy consultations it has worked on—the “Discussion Paper on Climate Risk and Sustainable Finance released by the Reserve Bank of India” and the “Consultation Paper on ESG Disclosures, Ratings and Investing published by the Securities and Exchange Board of India”—clarifying that its focus is on climate-related reporting rules in India. The bank is explicit about how it engages, stating that it communicates via “direct emails, workshops, seminars and through industry bodies” and that it also takes part in “pilots being conducted by the regulator relating to climate,” while identifying its principal targets as the Reserve Bank of India and the Securities and Exchange Board of India. However, beyond noting that it is “participating at various industry and regulatory forums for providing collaborative inputs on climate policy-making” and that it “support[s] the policies with minor exceptions,” the bank does not spell out the specific changes, thresholds, or amendments it is seeking. As a result, although its disclosure of mechanisms and policy titles is detailed, the desired outcomes of its lobbying remain largely generic.	2

Lobbying Governance

Overall Assessment	Comment	Score
None	ICICI Bank Ltd discloses no governance process to align its lobbying or policy engagement activities with climate goals. It explicitly states it does not have a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” and that “No, and we do not plan to have one in the next two years”. The company does not disclose any policy or process for reviewing and managing direct or indirect lobbying activities, nor does it identify any individual or committee responsible for oversight. We found no evidence of mechanisms to ensure alignment of its engagement with its climate strategy, indicating that governance of its lobbying activities is not addressed in its public disclosures.	0