Sanlam Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Sanlam discloses a structured governance system that integrates climate-related lobbying into its broader stakeholder-management architecture and assigns clear oversight. The company states that “the Social, Ethics and Sustainability Committee of the Sanlam Limited Board assumes responsibility for the governance of stakeholder management,” while “the Group Office and Business Clusters should report on a quarterly basis… to the Social, Ethics and Sustainability Committee of the Board,” demonstrating a recurring review cycle overseen by a named board committee. Direct advocacy is covered by the requirement that “the Group Compliance office engages with regulatory bodies, representing Sanlam position on policy related debates and forums,” and that any divergence from the firm’s climate strategy “would be shared with the Social, Ethics and Sustainability Committee of the Sanlam Board and decisions made accordingly,” indicating a mechanism to check that the company’s own lobbying aligns with its climate objectives. Indirect lobbying through trade bodies is also monitored: “any strategy direction of Association for Savings and Investments (ASISA) and South African Insurance Association (SAIA)… are monitored by Sanlam Investments and if divergent, will be taken to SIG Board level and then the Social, Ethics and Sustainability Committee of the Sanlam Board for review,” showing an escalation route to address misalignment with industry associations. The procedures apply equally when “stakeholder engagement calls for third-party advocacy, including lobbying of government or regulatory authorities,” which “must be managed in accordance with the guidelines in the SMSM to ensure responsible conduct with the appropriate level of transparency.” Responsibility for designing and tracking these processes is assigned to the “Head: Group Stakeholder Relations,” who must “develop metrics… implement StakeTracker… [and] report on a regular basis on material stakeholders and issues to Group Exco and the Sanlam Limited Board,” providing operational accountability. While this indicates strong governance covering both direct and indirect lobbying and names the bodies in charge, the company does not disclose a publicly available climate-lobbying alignment report nor evidence of undertaking or commissioning a formal audit of its lobbying positions, and it does not specify criteria for disengaging from misaligned associations; therefore only a solid, rather than comprehensive, governance framework is demonstrated. View Sources	3

Overall Assessment

Analysis

Score

Strong

Sanlam discloses a structured governance system that integrates climate-related lobbying into its broader stakeholder-management architecture and assigns clear oversight. The company states that “the Social, Ethics and Sustainability Committee of the Sanlam Limited Board assumes responsibility for the governance of stakeholder management,” while “the Group Office and Business Clusters should report on a quarterly basis… to the Social, Ethics and Sustainability Committee of the Board,” demonstrating a recurring review cycle overseen by a named board committee. Direct advocacy is covered by the requirement that “the Group Compliance office engages with regulatory bodies, representing Sanlam position on policy related debates and forums,” and that any divergence from the firm’s climate strategy “would be shared with the Social, Ethics and Sustainability Committee of the Sanlam Board and decisions made accordingly,” indicating a mechanism to check that the company’s own lobbying aligns with its climate objectives. Indirect lobbying through trade bodies is also monitored: “any strategy direction of Association for Savings and Investments (ASISA) and South African Insurance Association (SAIA)… are monitored by Sanlam Investments and if divergent, will be taken to SIG Board level and then the Social, Ethics and Sustainability Committee of the Sanlam Board for review,” showing an escalation route to address misalignment with industry associations. The procedures apply equally when “stakeholder engagement calls for third-party advocacy, including lobbying of government or regulatory authorities,” which “must be managed in accordance with the guidelines in the SMSM to ensure responsible conduct with the appropriate level of transparency.” Responsibility for designing and tracking these processes is assigned to the “Head: Group Stakeholder Relations,” who must “develop metrics… implement StakeTracker… [and] report on a regular basis on material stakeholders and issues to Group Exco and the Sanlam Limited Board,” providing operational accountability. While this indicates strong governance covering both direct and indirect lobbying and names the bodies in charge, the company does not disclose a publicly available climate-lobbying alignment report nor evidence of undertaking or commissioning a formal audit of its lobbying positions, and it does not specify criteria for disengaging from misaligned associations; therefore only a solid, rather than comprehensive, governance framework is demonstrated.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Sanlam discloses two named climate-related engagements—its input to the National Treasury’s draft technical paper “Financing a Sustainable Economy” and its advocacy on South Africa’s Climate Change Bill—while also citing its WWF partnership’s "strong advocacy role on all water legislature issues in South Africa," though without pinpointing specific statutes. It provides a high level of detail on its lobbying mechanisms and targets, explaining that it contributed to the draft paper via industry associations (ASISA and ASIA) directed at the National Treasury, participated in Business Unity South Africa’s dialogue with the Department of Forestry, Fisheries and the Environment, and engaged through the Presidential Climate Change Commission and at COP27. The company clearly articulates three desired outcomes for the sustainable finance paper—to harmonize definitions and disclosure standards, guide governance approaches, and develop a comprehensive sustainable finance framework—while its goals for water legislation and the Climate Change Bill remain broader, focused on improved water efficiency, quality, allocation, and greater specificity to support a just transition but without measurable targets. This combined disclosure demonstrates strong transparency on mechanisms, moderate transparency in naming policies, and moderate clarity on outcomes sought.	3