City Developments Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	City Developments Ltd discloses a wide range of climate-related public-policy engagements and generally explains them in detail, demonstrating a high level of transparency overall. The company names multiple specific measures it has worked on, including the Singapore Exchange “comply or explain” Sustainability Reporting Guidelines, the “Monetary Authority of Singapore’s green bond grant scheme,” the national “Carbon Pricing Bill,” and building-sector rules such as the “minimum environmental sustainability standard (Green Mark Standard) for existing buildings,” mandatory “periodic energy efficiency audits of building cooling systems,” and requirements to “submit information in respect of energy consumption” to the Commissioner of Building Control. CDL also sets out how it lobbies and who it targets: it has taken part in consultation sessions and briefings organised by SGX, held “meetings with government regulators on green financing,” provided building-energy data to the Building and Construction Authority, collaborated “closely with the Ministry of Sustainability and the Environment,” and engaged regulators through its Chief Sustainability Officer’s roles with the UNEP Finance Initiative Property Working Group and MAS’s Financial Centre Advisory Panel. The desired outcomes of these efforts are described for several initiatives—for example, the company sought to help “promot[e] and formulat[e]” SGX’s sustainability-reporting framework and to “kick-start the green finance industry” by advocating government facilitation and support—though for some other policies, such as the carbon tax, it indicates only general support without spelling out specific amendments or targets. Together, these disclosures offer clear insight into the policies addressed and the methods of engagement, while the articulation of policy goals is detailed for key areas but less complete across the full portfolio of issues.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	City Developments Ltd discloses broad sustainability oversight but provides almost no detail on how it governs lobbying activities. The company states that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement" and explains that it "started conducting materiality assessments annually" and tracks progress through its "CDL Future Value 2030 Sustainability Blueprint", which it says guides its "sustainability advocacy". However, these references describe general sustainability management rather than a specific mechanism for monitoring or aligning lobbying. While the CSR & CG Committee "meets at least once a year to review CDL’s sustainability performance" and, since 2016, the sustainability function "comes under the direct supervision of the Chief Executive Officer", the evidence does not indicate that these bodies review or control policy-advocacy positions, trade-association memberships, or any other form of lobbying. We found no disclosure of a dedicated procedure to evaluate direct or indirect lobbying, no mention of engaging with or exiting trade associations over climate misalignment, and no identification of an individual or committee tasked specifically with lobbying alignment. Accordingly, the company demonstrates only a high-level commitment to align unspecified “engagement activities” with Paris goals, without detailing governance structures or monitoring processes for lobbying alignment.	1