South32 Ltd

South32 has established a governance framework to align its climate-related advocacy through a formal approach to industry associations, but the company does not disclose a comparable process for its direct lobbying activities. The Board and its Sustainability Committee provide oversight of "material sustainability-related risks and opportunities, including ... climate change," and the CEO "together with our Lead Team, is accountable for execution of our approach to climate change." Since 2019, South32 has "undertaken an annual review of our member industry associations' policies on climate change and published our findings in our sustainability disclosures," strengthening this review at its 2021 AGM. The company further asserts that "we do not support direct advocacy from our industry association memberships on energy coal expansion or energy coal subsidies," and the FY24 review "considered available public documentation, including traditional and social media, speeches, submissions, website content and public statements," assessed against "the pre-determined set of criteria outlined in Appendix A," and factored in independent analysis from InfluenceMap. Any misalignment is "managed consistent with Our Approach to Industry Associations," with the option to cease membership. While these disclosures demonstrate a clear policy and dedicated monitoring process for indirect lobbying, the company does not disclose a specific procedure for reviewing or managing its own direct lobbying efforts.