South32 Ltd

The objective of the FY24 review was to assess for alignment with our climate change positions as detailed on page 73 of our Sustainable Development Report 2024. The review considered available public documentation, including traditional and social media, speeches, submissions, website content and public statements, with a focus on activity during FY24. Data was assessed against the pre-determined set of criteria outlined in Appendix A. The review also took into consideration analysis and reporting of industry association advocacy by InfluenceMap, an independent body mapping climate policy engagement of industry associations. Any potential misalignment is managed consistent with Our Approach to Industry Associations, including the circumstances under which we are prepared to cease our membership. Learn more at _www.south32.net ._

Our Board, together with its standing Committees, has oversight of our work on climate change as a material strategic and governance issue. The Board oversees the Company on its approach to delivering its decarbonisation commitments, recognising that it must be both ambitious – which is necessary to achieve our net zero goal – and realistic, recognising that there is no definitive 'best pathway' to net zero and some of the innovations we will need are not yet fully developed. Our CEO, together with our Lead Team, is accountable for execution of our approach to climate change. [...] We regularly engage our investors on our material environmental, social and governance topics and to hear their views on our approach to climate change, our progress, and our governance. [...] Our Board, together with the Sustainability Committee will oversee management's implementation and further development of this Plan, the development of subsequent Plans, and our progress in meeting our commitments. [...] Since 2019, we have undertaken an annual review of our member industry associations' policies on climate change and published our findings in our sustainability disclosures. At our 2021 Annual General Meeting, we committed to strengthening this review. Our latest review of industry associations found no material misalignments on climate change policy or advocacy.

**Advocacy and our climate change positions**

We engage 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 though our participation in industry associations.

We are committed to conducting direct advocacy and expect our industry associations to conduct advocacy activity in line with our climate change positions. 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.

Learn more about our approach to industry associations and our FY24 review here.

The Board is supported to maintain effective governance, accountability and oversight of sustainability management and performance through its Sustainability Committee. The Committee oversees our approach to material sustainability-related risks and opportunities, including in relation to safety, health, environment, social performance, business ethics and climate change. Our Board is also assisted by the Risk and Audit Committee and Remuneration Committee, as appropriate. [...] Our Board has oversight of our relationships with Indigenous, Traditional and Tribal Peoples, through regular reporting to the Sustainability Committee, annual updates about the implementation of our Innovate Reconciliation Action Plan, annual review and approval of our Sustainable Development Report, on-country engagement with Traditional Owners and special briefings about material risks and issues. [...] Since 2019, we have undertaken an annual review of our member industry associations' policies on climate change and published our findings in our sustainability disclosures. At our 2021 Annual General Meeting, we committed to strengthening this review. Our latest review of industry associations found no material misalignments on climate change policy or advocacy. [...] We do not support direct advocacy from our industry association memberships on energy coal expansion or energy coal subsidies, particularly in the absence of an associated position on technology development, to remain consistent with the Paris Agreement. However, we note that many of the industry associations we are a member of contain broad commodity representation, including energy coal producers, which can occasionally create differing views. Where advocacy for energy coal is undertaken, we manage potential misalignment consistent with Our Approach to Industry Associations, but on balance found no material instances in this year's review.