African Rainbow Minerals Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	African Rainbow Minerals describes a structured, board-level mechanism for overseeing climate-related advocacy. It states that the ARM board, through the social and ethics committee chaired by Dr Rejoice Simelane, has ultimate responsibility for climate-change management and that this committee monitors and reports on the manner and extent to which ARM protects, enhances and invests in the wellbeing of the economic, social and natural environments, clearly disclosing the body that oversees lobbying alignment. The company has also implemented a concrete procedure for indirect lobbying: In F2022, we assessed the climate-change policies and positions of the five industry associations of which ARM is a member to see how these align with ARMs 12 climate-change statements/commitments, with follow-up actions that include engaging the association where policy change is required or considering suspending our membership where material misalignment exists and a commitment to publicly disclose where our position differs on climate change. These statements, together with the note that ESG targets are included in the remuneration packages of relevant executives, indicate accountability and monitoring mechanisms. Nevertheless, we found no evidence of an equivalent, detailed process that governs the companys own direct lobbying activities beyond the intention to consider our direct and indirect lobbying on climate-related topics during association reviews, nor any stand-alone public climate-lobbying alignment report or third-party audit. This indicates moderate but not comprehensive governance of climate lobbying. View Sources	C

Overall Assessment

Analysis

Score

Moderate

African Rainbow Minerals describes a structured, board-level mechanism for overseeing climate-related advocacy. It states that the ARM board, through the social and ethics committee chaired by Dr Rejoice Simelane, has ultimate responsibility for climate-change management and that this committee monitors and reports on the manner and extent to which ARM protects, enhances and invests in the wellbeing of the economic, social and natural environments, clearly disclosing the body that oversees lobbying alignment. The company has also implemented a concrete procedure for indirect lobbying: In F2022, we assessed the climate-change policies and positions of the five industry associations of which ARM is a member to see how these align with ARMs 12 climate-change statements/commitments, with follow-up actions that include engaging the association where policy change is required or considering suspending our membership where material misalignment exists and a commitment to publicly disclose where our position differs on climate change. These statements, together with the note that ESG targets are included in the remuneration packages of relevant executives, indicate accountability and monitoring mechanisms. Nevertheless, we found no evidence of an equivalent, detailed process that governs the companys own direct lobbying activities beyond the intention to consider our direct and indirect lobbying on climate-related topics during association reviews, nor any stand-alone public climate-lobbying alignment report or third-party audit. This indicates moderate but not comprehensive governance of climate lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	African Rainbow Minerals offers only limited insight into its climate-related lobbying. It references broad policy areas—carbon budgets, carbon tax and alignment with the Paris Agreement—and notes compliance with “Climate Change Act 22 of 2024,” but it does not identify any particular bill numbers, draft regulations or other identifiable instruments it has tried to influence. The company sketches its channels of engagement, stating that it “has engaged directly with the DFFE” and that “We continue to engage as an active member of the ICMM through the climate change and water working groups,” yet it gives no detail on the form of those approaches (e.g., meetings, submissions, letters) and names only one specific policymaking body, the South African Department of Forestry, Fisheries and the Environment. On intended outcomes the disclosure remains general: the company says it “supports the move to a low-carbon economy,” wants “clarity on carbon tax allowances and offsets,” and is discussing “using carbon tax to support targeted mitigation actions,” but it stops short of stating the concrete legislative amendments, numerical targets or timeframes it is seeking. Taken together, the disclosures show acknowledgement of policy engagement but lack the specificity needed to demonstrate robust transparency.	D