Momentum Metropolitan Holdings – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Momentum Metropolitan integrates climate policy engagement within its sustainability governance, describing how “Momentum Metropolitan is represented by various business unit representatives who engage with Government, Regulators, Industry Bodies and Business Partners on policy issues impacting the business inclusive of climate change,” and noting that “the various representatives meet on a regular basis with their associations to debate and give recommendations on various topics to ensure sustainability in their business models.” It also holds a public commitment “to conduct your engagement activities in line with the goals of the Paris Agreement” and the Sustainability Department “incorporate[s] and report[s] on the Responsible Investments engagement activities to the SETC – feedback on issues is reported as per MMH’s Risk Management policy.” However, we found no disclosure of a dedicated lobbying governance policy or formal review process for advocacy positioning, no requirement for board‐level sign‐off of lobbying activities, and no named individual or committee explicitly tasked with overseeing the alignment of lobbying with its climate objectives. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Momentum Metropolitan integrates climate policy engagement within its sustainability governance, describing how “Momentum Metropolitan is represented by various business unit representatives who engage with Government, Regulators, Industry Bodies and Business Partners on policy issues impacting the business inclusive of climate change,” and noting that “the various representatives meet on a regular basis with their associations to debate and give recommendations on various topics to ensure sustainability in their business models.” It also holds a public commitment “to conduct your engagement activities in line with the goals of the Paris Agreement” and the Sustainability Department “incorporate[s] and report[s] on the Responsible Investments engagement activities to the SETC – feedback on issues is reported as per MMH’s Risk Management policy.” However, we found no disclosure of a dedicated lobbying governance policy or formal review process for advocacy positioning, no requirement for board‐level sign‐off of lobbying activities, and no named individual or committee explicitly tasked with overseeing the alignment of lobbying with its climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Momentum Metropolitan provides transparent details on its engagement with the Green Finance Taxonomy for South Africa, identifying National Treasury as the target when it “responded to the consultation and sent a written response to National Treasury on the Green Finance Taxonomy for South Africa.” The company has outlined the Taxonomy’s intended outcomes—curbing greenwashing, enhancing transparency and accountability, and aligning with international best practices to drive green market growth—and indicates support “with no exceptions.” Beyond this, however, references to other policies such as the South African Climate Change Bill and participation in industry bodies (SAIA, ASISA, Nedlac debates) remain broad, and the specific policymaking targets or lobbying methods (besides the one consultation response) are not described. While general aspirations—advancing a just transition and aligning with the Paris Agreement—are stated, the firm stops short of specifying measurable legislative or regulatory changes sought. Overall, the company delivers strong clarity on the Taxonomy initiative but offers limited disclosure on additional policy engagements and mechanisms.	C