South32 Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	South32 sets out a clear process to manage the climate-lobbying positions of the trade associations it funds, stating that Since 2019, we have undertaken an annual review of our member industry associations positions on climate change to evaluate alignment with our own positions, strategy and values and describing the FY24 exercise as an assessment of public documentation against the pre-determined set of criteria that also draws on InfluenceMap analysis. The company explains that Any potential misalignment is managed consistent with Our Approach to Industry Associations, including the circumstances under which we are prepared to cease our membership, demonstrating concrete escalation and corrective measures for indirect lobbying. Oversight is anchored at senior levels: The Board is supported through its Sustainability Committee and Our CEO, together with our Lead Team, is accountable for execution of our approach to climate change, indicating that both the Board and executive management review the climate programme, which includes policy engagement. South32 also records its stance on direct advocacy, noting that We engage on climate change related policy through direct advocacy and are committed to conducting direct advocacy in line with our climate change positions, yet it does not disclose a specific monitoring or sign-off procedure for its own lobbying activities beyond this statement. The absence of a detailed public audit of all lobbying, and the lack of explicit processes for tracking and validating the companys direct advocacy, mean the disclosure is strongest on indirect lobbying governance and weaker on direct lobbying controls. View Sources	C

Overall Assessment

Analysis

Score

Moderate

South32 sets out a clear process to manage the climate-lobbying positions of the trade associations it funds, stating that Since 2019, we have undertaken an annual review of our member industry associations positions on climate change to evaluate alignment with our own positions, strategy and values and describing the FY24 exercise as an assessment of public documentation against the pre-determined set of criteria that also draws on InfluenceMap analysis. The company explains that Any potential misalignment is managed consistent with Our Approach to Industry Associations, including the circumstances under which we are prepared to cease our membership, demonstrating concrete escalation and corrective measures for indirect lobbying. Oversight is anchored at senior levels: The Board is supported through its Sustainability Committee and Our CEO, together with our Lead Team, is accountable for execution of our approach to climate change, indicating that both the Board and executive management review the climate programme, which includes policy engagement. South32 also records its stance on direct advocacy, noting that We engage on climate change related policy through direct advocacy and are committed to conducting direct advocacy in line with our climate change positions, yet it does not disclose a specific monitoring or sign-off procedure for its own lobbying activities beyond this statement. The absence of a detailed public audit of all lobbying, and the lack of explicit processes for tracking and validating the companys direct advocacy, mean the disclosure is strongest on indirect lobbying governance and weaker on direct lobbying controls.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	South32 provides only a limited picture of its climate-related lobbying. The company confirms that it "engaged on climate-related policy developments and regulatory reform" and that it "engage[s] on climate change related policy through direct advocacy, such as engagement with policy makers and submissions to regulatory and policy reforms proposed by governments, and indirect advocacy through our participation in industry associations." These statements acknowledge both direct and association-based mechanisms, yet they stop short of naming the government bodies, officials or consultation processes involved. Likewise, South32 does not identify any specific legislation or regulatory proposals it has sought to influence, referring instead to broad areas such as carbon-pricing discussions or "climate-related policy developments." On objectives, the disclosures articulate only high-level aspirations—such as "work[ing] with key stakeholders towards securing stable and affordable low-carbon energy solutions" and ensuring advocacy that is "in line with our climate change positions"—without spelling out the concrete policy changes or measurable outcomes it pursues. As a result, while the company signals that lobbying activity occurs, it offers minimal detail on the particular policies, methods or end-goals of that engagement.	D