AECI Ltd

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	AECI provides evidence of a formal mechanism to keep its climate-related advocacy consistent with its broader sustainability strategy, but the disclosures remain high-level and do not extend to a detailed assessment of trade-association positions or a lobbying-alignment review. The company states that AECI ensures that all its direct and indirect activities that influence policy are consistent in terms of messaging through: Adherence to the SHEQ Policy and the Sustainability Strategy and Framework and central coordination of stakeholder engagement, and explains that If any inconsistencies are identified, these inconsistencies are raised with the Risk Committee and the Social and Ethics Committee who then implement the required actions. This indicates that there is an internal procedure to monitor and correct misalignment of both direct and indirect lobbying. Oversight is clearly allocated: the renamed social, ethics and sustainability committee (SESC) is a board committee, and the execution of our sustainability strategy falls under the ambit of the group head of sustainability and ESG, providing identifiable accountability for lobbying alignment. The company does provide very limited details on its alignment with several trade associations, climate lobbying (Chemical and Allied Industries Association (CAIA) and the National Business Initiative (NBI)). Though it is not disclosed a process to address trade associations' climate lobbying alignment or ensure any corrective actions where misalignments exists. References to political neutrality (Donations to political parties are prohibited) and to general sustainability dashboards do not detail how lobbying is monitored in practice. View Sources	C

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	AECI Ltd provides a clear and detailed picture of its climate-policy lobbying. It names three distinct South African measures it has engaged on—the “mandated carbon budgets,” the “mandatory reporting of GHG emissions in South Africa that was introduced in 2017,” and “The South African Carbon Tax”—situating each within the national climate-legislative framework. The company also explains how it lobbies, stating that it acts “through meetings and written correspondence” and identifying the specific target of those efforts as the “South African Department of Forestry, Fisheries and Environment” and other policymakers responsible for the carbon-tax regime. Finally, AECI lays out the concrete changes it seeks: it has “proposed changes to the boundaries and thresholds so that they align with other climate-related legislation,” called for better alignment between carbon budgets, Pollution Prevention Plans and the carbon tax, and suggested that “companies who can show that they have undertaken acceptable emissions mitigation activities should be exempt from the tax,” citing concerns about “the appropriateness and timing of the carbon tax” and “the way in which companies are benchmarked under the carbon tax.” Together, these disclosures demonstrate a strong level of transparency across the policies lobbied, the mechanisms employed and the specific outcomes pursued.	B