Kumba Iron Ore Ltd

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	Kumba Iron Ore Ltd demonstrates a comprehensive governance process for climate-related lobbying, with clear mechanisms for oversight, monitoring, and alignment. The company has established the Safety, Health and Sustainable Development (SHSD) Committee, which is tasked with "developing and reviewing climate-related policies and guidelines, monitoring performance against key climate indicators, and facilitating stakeholder engagement, co-operation and consultation on climate issues." The SHSD Committee, chaired by Mr. Terence Goodlace, meets quarterly and provides summaries of its discussions to the Board, ensuring that material issues are addressed. Additionally, Kumba has implemented a governance model for advocacy that emphasizes "transparency, high standards and clear accountability," ensuring that all climate-related advocacy aligns with the goals of the UNFCCC Paris Agreement. The company also discloses its memberships in industry associations on the Anglo American website, detailing the rationale for membership, positions held by employees, and financial contributions, allowing for public scrutiny. Furthermore, Anglo American commissions a biennial independent analysis to assess the alignment of industry associations with its climate policy positions, including climate science, carbon pricing, and just transition. The latest review identified "seven material differences" across 131 memberships, including two associations Kumba is part of, and actions were taken to engage with these associations. This indicates a robust governance framework that actively monitors and aligns both direct and indirect lobbying activities with climate goals, supported by external assurance and transparent reporting. View Sources	A

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Kumba Iron Ore offers only limited insight into its climate-policy lobbying. The company references headline agreements such as the Paris Agreement and, more generally, “the market-based emissions reduction mechanisms proposed in the Kyoto Protocol,” indicating the broad policy areas it follows, but it does not go further to name or describe any specific national or regional bills, regulations or rulemakings it has actively sought to influence. Disclosures on how it lobbies are similarly high-level: it says it will “monitor and participate in international processes,” “engage directly with the Minerals Council,” and that “any climate-related advocacy that we undertake or that is undertaken on our behalf through a third party… should be in line with the letter and the spirit of our stated policy positions,” yet it gives no detail on the format of that engagement (letters, meetings, submissions) or on the government bodies or individual officials approached. Finally, the outcomes the company seeks remain expressed only as broad aspirations—supporting “consistent carbon pricing policies across jurisdictions,” an “approach to climate transition that considers the societal impacts,” and alignment with the Paris goals—without translating these positions into concrete legislative changes, targets, or amendments it would like to see enacted. Together, the disclosure signals some commitment to responsible advocacy but leaves stakeholders with minimal clarity on the specific policies, channels and results the company is pursuing.	D