FirstRand Ltd

FirstRand discloses some governance elements that touch on climate-related stakeholder and policy engagement, but it provides only high-level references rather than a detailed system for monitoring and aligning lobbying activities. The company states that "guidelines and policies are in place to govern engagement with specific stakeholders" and that "the board, through Setcom, has ultimate responsibility for stakeholder engagement," indicating that a formal board sub-committee has oversight of how the group interacts with policymakers and other external parties. In response to a CDP question the group adds that it will pursue its net-zero ambition "through proactive and influential engagement with ... regulators on their public policies" and outlines that this engagement "has been shaped by ongoing active engagement with ... government departments and regulators on envisaged policy approaches," showing an intention to align advocacy with its climate strategy. However, we found no evidence of a structured review of either direct lobbying positions or membership in industry associations, no description of specific monitoring mechanisms, and no public audit or report evaluating whether advocacy is consistent with the company's climate goals. Consequently, while the disclosure identifies an accountable body and makes a general commitment to responsible engagement, the underlying processes, controls and alignment checks that would demonstrate stronger lobbying governance are not publicly detailed.