AvalonBay Communities Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	AvalonBay Communities discloses several internal mechanisms that link its policy-influencing activity to its climate objectives, indicating a moderate level of lobbying governance. It states that all of our direct and indirect activities that influence policy are consistent with our overall climate change strategy and outlines three processes to achieve this: first, all of our Companys procedures are governed by our corporate governance policies and principles, such as the Code of Business Conduct and Ethics and Corporate Governance Guidelines, which it says provide safeguards against practices that are inconsistent with the Companys objectives; second, the Vice President of Corporate Responsibility regularly interfaces with our Chief Investment Officer (CIO) and reports to our Chief Financial Officer [to] ensure that their knowledge of and participation in trade associations and advocacy is consistent with our overall climate change strategy; and third, through regular updates on ESG to the AvalonBay Board of Directors we ensure complete alignment at the top around the activities both internal and external (policy influence, for one) related to our climate change strategy. The disclosure therefore identifies a named executive (the VP of Corporate Responsibility) and the Board as oversight bodies and describes an internal review pathway for both direct lobbying and participation in trade associations, which signals governance coverage of indirect channels as well. However, the company does not disclose any systematic monitoring criteria, results of alignment reviews, or examples of how it has acted to correct or exit misaligned trade associations, nor does it publish a separate lobbying-alignment report; thus the transparency and detail of its monitoring remain limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

AvalonBay Communities discloses several internal mechanisms that link its policy-influencing activity to its climate objectives, indicating a moderate level of lobbying governance. It states that all of our direct and indirect activities that influence policy are consistent with our overall climate change strategy and outlines three processes to achieve this: first, all of our Companys procedures are governed by our corporate governance policies and principles, such as the Code of Business Conduct and Ethics and Corporate Governance Guidelines, which it says provide safeguards against practices that are inconsistent with the Companys objectives; second, the Vice President of Corporate Responsibility regularly interfaces with our Chief Investment Officer (CIO) and reports to our Chief Financial Officer [to] ensure that their knowledge of and participation in trade associations and advocacy is consistent with our overall climate change strategy; and third, through regular updates on ESG to the AvalonBay Board of Directors we ensure complete alignment at the top around the activities both internal and external (policy influence, for one) related to our climate change strategy. The disclosure therefore identifies a named executive (the VP of Corporate Responsibility) and the Board as oversight bodies and describes an internal review pathway for both direct lobbying and participation in trade associations, which signals governance coverage of indirect channels as well. However, the company does not disclose any systematic monitoring criteria, results of alignment reviews, or examples of how it has acted to correct or exit misaligned trade associations, nor does it publish a separate lobbying-alignment report; thus the transparency and detail of its monitoring remain limited.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	AvalonBay Communities provides a highly detailed picture of its climate-policy advocacy. It identifies the exact regulations it engages on – New York City’s Local Law 97, Washington DC’s Building Energy Performance Standards, Boston’s Building Emissions Reduction and Disclosure Ordinance, and Seattle’s proposed Building Emissions Performance Standards – leaving no ambiguity about which laws are in scope. The company also spells out how and with whom it acts, describing direct collaboration with municipal programmes such as “New York City’s Retrofit Accelerator Program,” supplying comments to the Washington DC Department of Energy & Environment, taking part in webinars on Seattle’s draft standards, and offering two properties to “Boston’s Green Ribbon commission” for pilot studies, thereby pairing each mechanism with a clearly named policymaking target. Finally, it is explicit about what it wants to achieve: helping New York City reach “an 80% emissions reduction by 2050,” supporting Boston’s drive for “carbon neutrality by 2050,” shaping the detailed implementation of DC’s BEPS, and proposing alternative compliance pathways for third-party leases. Statements such as “We will work with the city over the coming years to test and implement technologies to deeply cut emissions in these buildings” and “Our participation in the program will help the city better understand how buildings can be retrofitted to dramatically reduce carbon emissions” demonstrate clear, measurable objectives linked to each lobbying effort. Together these disclosures show comprehensive transparency across the policies addressed, the engagement channels used, and the concrete outcomes sought.	A