Sappi Ltd

Sappi Ltd has formalized its approach to aligning policy engagement with its climate priorities by stating that "our engagement activities are guided by the TCFD, our support of the Paris Agreement since it was first drawn up, our commitments to the SBTi, the priority targets we have established in alignment with climate-relevant UN SDs, including SDG7: Renewable and Clean Energy and SDG13: Climate Action, as well as with our Climate Policy." Sappi further confirms that it "conduct[s] [its] engagement activities in line with the goals of the Paris Agreement." This framework is operationalized through a defined review process whereby "the Group Heads of Investor Relations and Sustainability; Corporate Affairs and Strategy and Legal liaise with the regional CEOS and sustainability heads regarding direct activities that influence policy," and "all public statements that influence policy have to be approved by the Group Head: Corporate Affairs, who also reviews public statements to ensure that they remain consistent with our overall climate change strategy." While these measures demonstrate accountability and oversight of direct lobbying efforts, we found no evidence of governance mechanisms for managing indirect lobbying through trade or industry associations, and no publicly available third-party audit or board-level sign-off specifically addressing climate-lobbying alignment.