Sappi Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Sappi provides a high level of transparency on its climate-policy lobbying. It names multiple specific measures it has engaged on—the EU Deforestation Regulation, South Africa’s Carbon Tax Act, the U.S. Inflation Reduction Act, and elements of the EU “European Green Deal / Fit for 55” package—covering three jurisdictions and clearly identifying each policy. The company also explains how it seeks to influence these files: it "engaged with the Department of Forestry, Fisheries and the Environment (DFFE)" in South Africa over carbon-tax calculations, submitted two concept papers to the U.S. federal government for funding under the IRA, and works through the Confederation of European Paper Industries to reach EU policymakers on the Green Deal, thereby disclosing both the mechanisms (direct meetings, formal submissions, trade-association advocacy) and the specific governmental targets. Finally, Sappi sets out concrete objectives for each engagement, including winning recognition of plantation carbon sequestration in South Africa’s carbon-tax framework—"We strongly believe that the sequestration potential of our plantations should be recognised and accounted for"—securing US$249 million of IRA funding for biomass and packaging decarbonisation projects, and ensuring EU industry has access to “affordable, renewable and low-carbon energy” within the Green Deal. The combination of detailed policy references, clear descriptions of lobbying channels and targets, and explicit, measurable outcomes demonstrates comprehensive disclosure of its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Sappi Ltd has formalized its approach to aligning policy engagement with its climate priorities by stating that “our engagement activities are guided by the TCFD, our support of the Paris Agreement since it was first drawn up, our commitments to the SBTi, the priority targets we have established in alignment with climate-relevant UN SDs, including SDG7: Renewable and Clean Energy and SDG13: Climate Action, as well as with our Climate Policy.” Sappi further confirms that it “conduct[s] [its] engagement activities in line with the goals of the Paris Agreement.” This framework is operationalized through a defined review process whereby “the Group Heads of Investor Relations and Sustainability; Corporate Affairs and Strategy and Legal liaise with the regional CEOS and sustainability heads regarding direct activities that influence policy,” and “all public statements that influence policy have to be approved by the Group Head: Corporate Affairs, who also reviews public statements to ensure that they remain consistent with our overall climate change strategy.” While these measures demonstrate accountability and oversight of direct lobbying efforts, we found no evidence of governance mechanisms for managing indirect lobbying through trade or industry associations, and no publicly available third-party audit or board-level sign-off specifically addressing climate-lobbying alignment.	2