FirstRand Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	FirstRand Ltd is highly transparent about its climate-related lobbying. It names a broad suite of specific policies it has engaged on, including the Sustainable Finance Technical Paper issued by the National Treasury, the South African Green Taxonomy, TCFD Guidance and Principles for Disclosure, the Carbon Tax Act (and earlier draft bills and discussion papers), the South African Climate Change Bill, the country’s updated nationally determined contributions, and the National Greenhouse Gas Emission Reporting Regulations. The company also spells out how and where it lobbies: it sits on National Treasury working groups for sustainable finance and taxonomy development; participates in Business Unity South Africa (BUSA) technical committees and meetings that interface with the Department of Environment, Forestry and Fisheries, the Department of Energy, and the South African Reserve Bank; and is represented at the Presidential Climate Commission through BUSA, BASA and the National Business Initiative, where it submits comments and raises concerns in public sessions. Finally, FirstRand is explicit about the outcomes it seeks. It is “supportive of the Sustainable Finance Technical Paper” and aims to “ensure alignment with National Treasury as the regulatory and guidance framework evolves”; it backs a market-based mechanism for reducing emissions but “proposed that carbon tax revenue be ring-fenced for national climate change adaptation and mitigation activities”; it has “concern that the updated NDCs are not ambitious enough to achieve net-zero emissions by 2050”; and it advocates adjustments to pollution-prevention reporting guidelines. By detailing the policies, the channels of influence, the government bodies addressed, and the concrete legislative or regulatory changes it supports or opposes, the company demonstrates a comprehensive level of transparency in its climate policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	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.	1