Tsogo Sun Limited – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Tsogo Sun Limited reports that “Through CASA, the group: [...] Commented on and made oral representations to the KwaZulu Natal Provincial Legislature on the KwaZulu-Natal Gaming and Betting Amendment Bill; [...] Commented on draft Rules relating to responsible measures published by the Western Cape Gambling and Racing Board; [...] Is preparing a comprehensive submission to Parliament in relation to the Control of Tobacco Products and Electronic Delivery Bill” and outlines that “Gaming regulation compliance … is achieved through the strict implementation of internal control procedures and compliance policies, engagement with regulators and law enforcement agencies, centralised specialist understanding …, compliance audits by internal and external auditors and by creating a compliance culture through training.” It also notes that “The social and ethics committee is constituted as a statutory committee of the company … to perform the prescribed statutory duties” and that its work includes “Monitoring legislative developments” and “Monitoring the group’s environmental management and its impact on the environment.” However, the company does not disclose any governance framework for lobbying activities—there is no description of how lobbying is aligned or reviewed, no policy or process for managing direct or indirect lobbying, and no specific individual or formal body explicitly tasked with overseeing lobbying alignment with the company’s objectives. View Sources	0

Overall Assessment

Analysis

Score

None

Tsogo Sun Limited reports that “Through CASA, the group: [...] Commented on and made oral representations to the KwaZulu Natal Provincial Legislature on the KwaZulu-Natal Gaming and Betting Amendment Bill; [...] Commented on draft Rules relating to responsible measures published by the Western Cape Gambling and Racing Board; [...] Is preparing a comprehensive submission to Parliament in relation to the Control of Tobacco Products and Electronic Delivery Bill” and outlines that “Gaming regulation compliance … is achieved through the strict implementation of internal control procedures and compliance policies, engagement with regulators and law enforcement agencies, centralised specialist understanding …, compliance audits by internal and external auditors and by creating a compliance culture through training.” It also notes that “The social and ethics committee is constituted as a statutory committee of the company … to perform the prescribed statutory duties” and that its work includes “Monitoring legislative developments” and “Monitoring the group’s environmental management and its impact on the environment.” However, the company does not disclose any governance framework for lobbying activities—there is no description of how lobbying is aligned or reviewed, no policy or process for managing direct or indirect lobbying, and no specific individual or formal body explicitly tasked with overseeing lobbying alignment with the company’s objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Tsogo Sun Limited offers only minimal transparency about its climate-related lobbying. It indicates that it comments on legislative proposals and participates in industry forums such as CASA, which shows a basic disclosure of one lobbying channel, but it does not name the government bodies or officials it targets. The company does not identify any specific climate policies, laws or regulations it has sought to influence, nor does it clarify whether its work through CASA relates to climate matters at all. Likewise, it provides no explanation of the policy changes or outcomes it is trying to secure through these activities. As a result, readers gain very limited insight into the company’s actual climate-policy lobbying agenda or objectives.	1