Old Mutual Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Old Mutual Ltd demonstrates a moderate level of governance in its climate lobbying processes, with several structures and mechanisms in place to align its activities with climate-related goals. The company has established a Climate Change Task Force, which is tasked with "coordinating and overseeing 4 cross-functional work stream activities; ensuring alignment across functional areas and segments," and ensuring compliance with "regulatory and TCFD disclosure requirements." This task force facilitates integration and alignment of business unit activities with the directions set by the Climate Change Task Force, indicating a structured approach to climate-related governance. Additionally, the Responsible Business committee and Risk committee provide oversight over sustainability and climate mandates, and the Board is accountable for the Group’s overall performance, including climate-related issues. However, while the company mentions engagement with government, regulators, and industry bodies on policy issues, including climate change, there is no explicit disclosure of a detailed process for monitoring or managing lobbying alignment, nor evidence of a comprehensive audit or review of lobbying activities. Furthermore, while the governance structures are robust in addressing climate risks and opportunities, the evidence does not clearly describe how direct and indirect lobbying activities are actively aligned with the company’s climate strategy. The company does not disclose specific criteria for assessing its participation in associations or actions taken to correct or exit associations whose positions conflict with its climate policy. This indicates that while there are strong governance structures for climate-related issues, the transparency and specificity of lobbying governance processes remain limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Old Mutual Ltd demonstrates a moderate level of governance in its climate lobbying processes, with several structures and mechanisms in place to align its activities with climate-related goals. The company has established a Climate Change Task Force, which is tasked with "coordinating and overseeing 4 cross-functional work stream activities; ensuring alignment across functional areas and segments," and ensuring compliance with "regulatory and TCFD disclosure requirements." This task force facilitates integration and alignment of business unit activities with the directions set by the Climate Change Task Force, indicating a structured approach to climate-related governance. Additionally, the Responsible Business committee and Risk committee provide oversight over sustainability and climate mandates, and the Board is accountable for the Group’s overall performance, including climate-related issues. However, while the company mentions engagement with government, regulators, and industry bodies on policy issues, including climate change, there is no explicit disclosure of a detailed process for monitoring or managing lobbying alignment, nor evidence of a comprehensive audit or review of lobbying activities. Furthermore, while the governance structures are robust in addressing climate risks and opportunities, the evidence does not clearly describe how direct and indirect lobbying activities are actively aligned with the company’s climate strategy. The company does not disclose specific criteria for assessing its participation in associations or actions taken to correct or exit associations whose positions conflict with its climate policy. This indicates that while there are strong governance structures for climate-related issues, the transparency and specificity of lobbying governance processes remain limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Old Mutual Ltd offers a relatively detailed picture of its climate-policy engagement. It names several concrete policies it has worked on, including the South African “Green Finance Taxonomy,” the Johannesburg Stock Exchange “Sustainability and Climate Disclosure Guidance,” and input to the government’s “Just Energy Transition Investment Plan,” demonstrating transparency about the specific rules it seeks to influence. The company also discloses how and with whom it engages: it “proactively engaged the National Treasury Working Group on developing the Green Finance Taxonomy for South Africa” and “provided feedback during the consultative process to the JSE regarding its Sustainability and Climate Disclosure Guidance,” thereby identifying both the methods (proactive engagement, formal consultation feedback) and the targets (National Treasury Working Group and the JSE). While only two mechanisms are described in detail, they show direct interaction with identifiable public-sector bodies. Old Mutual is explicit about the policy changes it wants, stating its “support for the Green Finance Taxonomy ‘with no exceptions’” to “open the market for green economic growth” and that the JSE guidance should “promote transparency and good governance and guide listed companies on best practice in ESG disclosure.” These clearly articulated positions on at least two separate measures indicate a defined lobbying objective rather than vague aspirations. Taken together, these disclosures reflect a strong, though not exhaustive, level of transparency around the company’s climate-related lobbying activities.	B