ZIM Integrated Shipping Services Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	ZIM Integrated Shipping Services discloses a basic governance structure that touches on climate-related engagement, stating that "ZIM has a management level steering committee overlooked by board and CEO" whose purpose is "to ensure the organizations' ESG strategy is consistent with the day to day activity" and that this arrangement is meant to keep "engagement activities…consistent with your overall climate change strategy." The presence of a named steering committee reporting to the Board and Chief Executive demonstrates senior-level oversight as well as a stated mechanism for aligning external engagement with the company’s climate objectives, which indicates moderate governance. Nevertheless, the disclosure stops short of describing how lobbying or policy advocacy is monitored in practice, provides no detail on whether reviews cover both the company’s own lobbying and that of any trade associations, and offers no information on the frequency, criteria, or outcomes of such reviews. We found no evidence of a public lobbying-alignment report, third-party audit, or any corrective actions taken when misalignment is detected, so the breadth and effectiveness of the governance framework remain unclear. View Sources	C

Overall Assessment

Analysis

Score

Moderate

ZIM Integrated Shipping Services discloses a basic governance structure that touches on climate-related engagement, stating that "ZIM has a management level steering committee overlooked by board and CEO" whose purpose is "to ensure the organizations' ESG strategy is consistent with the day to day activity" and that this arrangement is meant to keep "engagement activities…consistent with your overall climate change strategy." The presence of a named steering committee reporting to the Board and Chief Executive demonstrates senior-level oversight as well as a stated mechanism for aligning external engagement with the company’s climate objectives, which indicates moderate governance. Nevertheless, the disclosure stops short of describing how lobbying or policy advocacy is monitored in practice, provides no detail on whether reviews cover both the company’s own lobbying and that of any trade associations, and offers no information on the frequency, criteria, or outcomes of such reviews. We found no evidence of a public lobbying-alignment report, third-party audit, or any corrective actions taken when misalignment is detected, so the breadth and effectiveness of the governance framework remain unclear.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	ZIM Integrated Shipping Services is reasonably clear about which climate regulations affect its business, explicitly referencing the FuelEU Maritime Regulation and the “European Union Emissions Trading System (EU ETS),” including details such as the EU ETS “will be in effect from January 1st, 2024” and its requirement that vessels “report their emissions and purchase an equivalent number of allowances on the EU ETS market.” However, the company gives no information about how it tries to shape these rules: there is no disclosure of meetings, letters, consultation submissions, coalition work, or any identification of the policymakers or bodies it might approach. Equally, beyond stating that it intends to comply—by “shifting to lower-emissions fuels” for FuelEU Maritime and introducing a New Emission Fee for the EU ETS—it does not set out any policy changes it supports or opposes, nor any broader advocacy objectives. As a result, while the policies in question are clearly named, the company provides almost no transparency about its lobbying methods or the outcomes it seeks.	D