KAP Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	KAP’s disclosures show that it “maintains open and transparent relationships with key government institutions and other regulatory authorities through engagement and active participation in industry associations” and that “we have formulated a government relations strategy to guide and enhance interactions with government and regulatory institutions.” These activities, which include supporting “South Africa’s climate strategy and environmental and waste management legislation,” are overseen by the “social and ethics committee, which is both a statutory committee and a committee of the board of directors,” indicating that lobbying efforts are subject to board-level review. The company also notes that “we are actively involved in the legislative process by commenting on new legislation and guidance issued by tax authorities and by lobbying for legislative change where required, either directly or through representative bodies.” However, KAP does not disclose any dedicated process for monitoring or managing the alignment of its climate-related lobbying, such as assessing advocacy positions against its climate objectives, setting criteria for engagement with industry bodies, or publishing an audit or report on lobbying alignment, and the social and ethics committee’s role is described in broad terms of “oversight and reporting on organisational ethics” rather than a targeted climate-lobbying governance function. View Sources	D

Overall Assessment

Analysis

Score

Limited

KAP’s disclosures show that it “maintains open and transparent relationships with key government institutions and other regulatory authorities through engagement and active participation in industry associations” and that “we have formulated a government relations strategy to guide and enhance interactions with government and regulatory institutions.” These activities, which include supporting “South Africa’s climate strategy and environmental and waste management legislation,” are overseen by the “social and ethics committee, which is both a statutory committee and a committee of the board of directors,” indicating that lobbying efforts are subject to board-level review. The company also notes that “we are actively involved in the legislative process by commenting on new legislation and guidance issued by tax authorities and by lobbying for legislative change where required, either directly or through representative bodies.” However, KAP does not disclose any dedicated process for monitoring or managing the alignment of its climate-related lobbying, such as assessing advocacy positions against its climate objectives, setting criteria for engagement with industry bodies, or publishing an audit or report on lobbying alignment, and the social and ethics committee’s role is described in broad terms of “oversight and reporting on organisational ethics” rather than a targeted climate-lobbying governance function.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	KAP Industrial Holdings Limited provides only limited insight into its climate-related lobbying. It indicates that it is involved in “the Plastics Industry Master Plan” and the “South African Automotive Master Plan 2035,” and refers generally to shaping South Africa’s climate strategy, but it does not name any specific pieces of climate legislation or regulations, nor does it confirm that these are the only policy areas in which it lobbies. The company notes that it collaborates with government bodies such as the Department of Trade, Industry and Competition, the Department of Cooperative Governance and Traditional Affairs, and local municipalities, yet it fails to describe the concrete mechanisms used—such as meetings, submissions or letters—through which these bodies are approached. Finally, the disclosures speak only in broad terms about intentions to “support government’s industrialisation strategy” and, quoting the company, “we are committed to reducing our environmental footprint and have adopted energy, water and waste strategies to deliver on this initiative,” without specifying what changes to policy or regulations it is actually seeking. Together, these omissions mean stakeholders receive only a high-level picture of the company’s lobbying activity rather than a clear account of the policies addressed, the methods employed, and the precise outcomes pursued.	D