Impala Platinum Holdings Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Impala Platinum discloses some mechanisms linking its climate strategy with the way it engages externally, indicating a degree of governance over climate-related advocacy. The company states that “the Board of Directors (including the CEO) is the custodian of the [Climate Change] Policy Statement and takes ultimate responsibility for ensuring that all activities, including engagement activities, are carried out in accordance with the commitments and principles outlined therein,” showing a high-level policy commitment to align advocacy with climate goals. Oversight responsibility is clearly assigned: “Our board is ultimately responsible for providing oversight on the Company responses to climate change,” while the Health, Safety and Environment (HSE) and Social, Transformation and Remuneration (STR) committees jointly address “Regulatory compliance” and “Policy advocacy,” and their chairs sit on each other’s committee to “enhance integrated thinking.” The company also notes that it “continuously monitors global and host-country regulatory changes related to climate change … [and] each quarter, we update the board on material developments,” implying a recurring review channel. However, the disclosure does not explain the specific procedures used to test whether direct lobbying positions or membership in trade associations are consistent with the Group’s climate policy, nor does it describe any corrective actions, escalation routes, or published alignment reports; the only detail offered is the Board’s general assurance that engagement activities follow the policy. No information is provided on how lobbying undertaken by industry associations is tracked or whether the company would challenge, amend or leave misaligned organisations. Therefore, while there is a documented policy commitment and identified oversight bodies, the absence of a transparent, detailed monitoring process for both direct and indirect lobbying and the lack of any public alignment review indicates only a moderate level of lobbying governance disclosure. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Impala Platinum discloses some mechanisms linking its climate strategy with the way it engages externally, indicating a degree of governance over climate-related advocacy. The company states that “the Board of Directors (including the CEO) is the custodian of the [Climate Change] Policy Statement and takes ultimate responsibility for ensuring that all activities, **including engagement activities**, are carried out in accordance with the commitments and principles outlined therein,” showing a high-level policy commitment to align advocacy with climate goals. Oversight responsibility is clearly assigned: “Our board is ultimately responsible for providing oversight on the Company responses to climate change,” while the Health, Safety and Environment (HSE) and Social, Transformation and Remuneration (STR) committees jointly address “Regulatory compliance” and “Policy advocacy,” and their chairs sit on each other’s committee to “enhance integrated thinking.” The company also notes that it “continuously monitors global and host-country regulatory changes related to climate change … [and] each quarter, we update the board on material developments,” implying a recurring review channel. However, the disclosure does not explain the specific procedures used to test whether direct lobbying positions or membership in trade associations are consistent with the Group’s climate policy, nor does it describe any corrective actions, escalation routes, or published alignment reports; the only detail offered is the Board’s general assurance that engagement activities follow the policy. No information is provided on how lobbying undertaken by industry associations is tracked or whether the company would challenge, amend or leave misaligned organisations. Therefore, while there is a documented policy commitment and identified oversight bodies, the absence of a transparent, detailed monitoring process for both direct and indirect lobbying and the lack of any public alignment review indicates only a moderate level of lobbying governance disclosure.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Impala Platinum Holdings provides some visibility into the climate policies it engages on, naming South Africa’s proposed “Climate Change Bill,” the existing “GHG Reporting Regulations,” and work on the country’s “carbon budgets and how the methodologies related to the application of the carbon budgeting system should be applied.” However, beyond stating that “Implats engages with government on matters related to climate change legislation,” the company gives no detail on the form that engagement takes—such as meetings, written submissions, or participation in consultations—nor does it identify which ministries, agencies, or officials it targets. The disclosure is also silent on what it hopes to achieve through these interactions; it does not state whether it supports, opposes, or seeks amendments to the bill, the reporting rules, or the carbon-budgeting methodology. As a result, while the policies being lobbied are reasonably clear, the mechanisms and desired outcomes remain largely opaque, yielding only a limited level of overall transparency.	D