Pan American Silver Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Pan American Silver Corp’s disclosures emphasize oversight of climate-related issues and sustainability, but they do not disclose any framework specifically governing lobbying activities or the alignment of lobbying with climate objectives. For example, the company states that “The Board of Directors … oversees and monitors and, if applicable, provides guidance with respect to the development of Pan American Silver’s goals, annual targets, policies and programs as they relate to climate change and GHG emissions,” and highlights that “The senior management ESG Committee develops climate change policy and provides standard recommendations to our Board committees,” but there is no disclosure of any process for reviewing or approving lobbying positions, no evidence of direct or indirect lobbying alignment mechanisms, and no identification of an individual or committee accountable for lobbying oversight. We found no evidence of a policy to ensure alignment of climate lobbying activities, no monitoring or management procedures related to lobbying, and no mention of exit or engagement strategies with trade associations, indicating an absence of a climate-lobbying governance framework. View Sources	E

Overall Assessment

Analysis

Score

None

Pan American Silver Corp’s disclosures emphasize oversight of climate-related issues and sustainability, but they do not disclose any framework specifically governing lobbying activities or the alignment of lobbying with climate objectives. For example, the company states that “The Board of Directors … oversees and monitors and, if applicable, provides guidance with respect to the development of Pan American Silver’s goals, annual targets, policies and programs as they relate to climate change and GHG emissions,” and highlights that “The senior management ESG Committee develops climate change policy and provides standard recommendations to our Board committees,” but there is no disclosure of any process for reviewing or approving lobbying positions, no evidence of direct or indirect lobbying alignment mechanisms, and no identification of an individual or committee accountable for lobbying oversight. We found no evidence of a policy to ensure alignment of climate lobbying activities, no monitoring or management procedures related to lobbying, and no mention of exit or engagement strategies with trade associations, indicating an absence of a climate-lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E