Discovery Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Discovery Ltd provides extensive, policy-specific disclosure of its climate-related lobbying. It identifies a wide range of concrete measures it has engaged on, including the “South Africa Prudential Authority Climate Risk Indicators”, the “National Health Insurance (NHI) Act”, the “JSE Climate and Sustainability Disclosure Guidance”, the “International Sustainability Standards Board exposure drafts”, South Africa’s draft “National Green Finance Taxonomy”, the “Climate Change Bill”, and other named regulatory proposals. The company also spells out how and where it intervenes: it “attend[ed] PACTT industry workshops”, “provided comments (through the PRI collaboration platform)” to National Treasury, “respond[ed] to the JSE’s request for comments”, and took part in “public-private dialogues” on the NHI Act, explicitly targeting bodies such as the South African Prudential Authority, National Treasury, the JSE and other financial-sector regulators. Finally, Discovery is clear about the outcomes it seeks, for example supporting the Climate Risk Indicators’ “finalisation of draft indicators and the provision of further clarity and guidance”, seeking amendments so that the NHI Act “is workable without private sector collaboration”, and aiming to “strengthen disclosures of listed companies” through the JSE guidance and ISSB standards. This combination of named policies, described engagement channels with identifiable decision-makers, and explicit policy objectives demonstrates a high level of transparency in the company’s climate-policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Discovery Ltd has put in place formal structures to align its lobbying and advocacy activities with its climate change strategy, with both direct engagements and indirect association memberships subject to oversight by a dedicated committee. For example, Any key advocacy engagements or engagement opportunities are shared with and tabled at this Steering Committee for consideration to ensure consistency with Group strategy and policy, demonstrating a clear process for screening and approving direct advocacy. Indirect lobbying through industry associations is also governed, as shown by the fact that Discovery is a member of a number of industry forums and professional associations with senior staff attending meetings and conferences regularly and that Membership of and participation at industry forums are considered and approved through this committee structure. Additionally, the company explains that There is also an internal approval process in place for regulatory submissions (including those related to climate change matters for consultation) which ensures that any views put forward are consistent with Discoverys climate change strategy, illustrating a mechanism to monitor positions before publication. These activities are overseen by the Discovery Group Climate Change Steering Committee, supported by the Group Chief Risk Officer as executive sponsor. The company does not disclose a publicly available audit or third-party review of its climate-lobbying alignment.	3