Woolworths Holdings Ltd/South Africa – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Woolworths Holdings Ltd discloses several governance structures and committees, such as the WHL Board Sustainability Committee and the WHL Board Social and Ethics Committee, which oversee aspects of its Good Business Journey (GBJ) strategy and stakeholder engagement. The company states that "the WHL Board is ultimately responsible for the GBJ," with operational responsibility delegated to the CEO and executive committees, including the Group Head of Sustainability and Director of Corporate Affairs. These teams report twice yearly against sustainability and corporate scorecards. Additionally, the Social and Ethics Committee conducts annual stakeholder engagement self-assessment reviews and ensures that the stakeholder management approach is ethical and transparent. Woolworths also mentions engaging with national governments and NGOs to promote greener businesses and has a dedicated stakeholder relationships manager with a strategy for engaging policymakers. However, while these disclosures indicate some governance mechanisms for stakeholder engagement and sustainability, there is no explicit evidence of a detailed process for aligning lobbying activities—direct or indirect—with climate goals. The company does not disclose a policy or process for monitoring or managing lobbying alignment with climate-related objectives, nor does it provide evidence of actions taken to ensure such alignment. Furthermore, Woolworths explicitly states that it does not have a public commitment to align its engagement activities with the goals of the Paris Agreement and does not plan to adopt one in the next two years. This indicates limited governance in the specific area of climate lobbying alignment. View Sources	1

Overall Assessment

Analysis

Score

Limited

Woolworths Holdings Ltd discloses several governance structures and committees, such as the WHL Board Sustainability Committee and the WHL Board Social and Ethics Committee, which oversee aspects of its Good Business Journey (GBJ) strategy and stakeholder engagement. The company states that "the WHL Board is ultimately responsible for the GBJ," with operational responsibility delegated to the CEO and executive committees, including the Group Head of Sustainability and Director of Corporate Affairs. These teams report twice yearly against sustainability and corporate scorecards. Additionally, the Social and Ethics Committee conducts annual stakeholder engagement self-assessment reviews and ensures that the stakeholder management approach is ethical and transparent. Woolworths also mentions engaging with national governments and NGOs to promote greener businesses and has a dedicated stakeholder relationships manager with a strategy for engaging policymakers. However, while these disclosures indicate some governance mechanisms for stakeholder engagement and sustainability, there is no explicit evidence of a detailed process for aligning lobbying activities—direct or indirect—with climate goals. The company does not disclose a policy or process for monitoring or managing lobbying alignment with climate-related objectives, nor does it provide evidence of actions taken to ensure such alignment. Furthermore, Woolworths explicitly states that it does not have a public commitment to align its engagement activities with the goals of the Paris Agreement and does not plan to adopt one in the next two years. This indicates limited governance in the specific area of climate lobbying alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Woolworths Holdings Ltd provides a high level of detail on its climate-policy lobbying. It names three concrete measures it has engaged on—the “proposed carbon tax” in South Africa, the South African “National Greenhouse Gas reporting regulations,” and disclosure obligations under Australia’s “National Greenhouse and Energy Reporting Act (2007)”—showing clear transparency on the policies involved. The company also explains how it tries to influence these measures, citing “focused workshops” and “commentary on legislative requirements,” “submitting its carbon tax assessment to the revenue services,” and direct or forum-based meetings with identified targets such as the “National Treasury and the Department of Energy in South Africa,” thereby giving specific mechanisms and targets. On desired outcomes, the company states that it “support[s] the proposed carbon tax in South Africa without exceptions,” seeks ongoing compliance with mandatory greenhouse-gas reporting rules, and aligns its actions with the Paris Agreement, indicating explicit policy goals even if not all contain quantitative detail. Collectively, these disclosures demonstrate strong transparency around the company’s climate lobbying activities.	3