Ninety One Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Ninety One Ltd provides a very detailed picture of its climate-policy engagement. It identifies concrete initiatives it has lobbied on, such as the UK Treasury-sponsored Transition Plan Taskforce, South Africa’s Just Energy Transition Investment Plan, the push for mandatory TCFD-aligned disclosure, and the sovereign sustainability-linked bond frameworks of Chile and Uruguay that culminated in Uruguay revising its NDC. The company also spells out how it influences policy: it describes co-authoring a letter to the South African Government in its role as a Climate Action 100+ co-lead on Eskom, holding direct discussions with the Governments of Chile and Uruguay – including Uruguay’s Ministry of Environment – and meeting members of the UK Cabinet, US Treasury and European Commission about the South African Just Energy Transition Partnership, alongside wider industry collaboration through platforms such as the Climate Finance Mobilisation Forum. Finally, Ninety One sets clear objectives for these efforts, seeking alignment of Uruguay’s NDC with Paris goals, a 1.5 °C-compatible decarbonisation pathway and stronger NDCs for South Africa, and increased development capital and policy support for Eskom and the wider Just Energy Transition Partnership. This clarity around the policies addressed, the mechanisms employed, and the specific outcomes pursued reflects a comprehensive level of transparency in its climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Ninety One Ltd discloses detailed case studies of its climate-related advocacy — for example, “Our advocacy for net-zero targets that incentivise real-world, inclusive decarbonisation has included discussions with the Institutional Investors Group on Climate Change (IGCC)” and its engagement in responding to the FCA’s Sustainability Disclosure Requirements — and it confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” with a clear “Yes.” However, we found no evidence of any internal governance mechanisms such as a defined review process, oversight by a named individual or committee, or procedures to monitor and align both direct and indirect lobbying. The company does not disclose who oversees these engagement activities or how they are assessed or audited for alignment with its climate strategy, indicating limited governance processes for its lobbying efforts.	1