Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Strong |
Sims Ltd describes a coordinated, multi-layered process that links climate lobbying to its overall climate strategy, indicating strong governance. The company states that “day-to-day engagements are coordinated via either the Director, Community & Government and/or the Director, Sustainability & CSR”, and that these named executives “report to the Board SHECS Committee and Risk Committee”, demonstrating clear lines of oversight up to board-level committees. It further notes “there is a formal approval process for public statements…including the Director of Investor Relations, the Chief Risk & Compliance Officer and the Head of Communication & Marketing”, showing a defined sign-off mechanism for its direct advocacy and submissions. For indirect lobbying, Sims explains that it “conducted a review of industry associations in FY22 to assess their alignment with our policy”, using criteria focused on whether the body “engages in or contributes to the climate change discussion” and confirms the review was undertaken by the Sustainability team with input from Ethics & Compliance and Government Engagement functions; it intends to repeat this process “every other year or when there is a significant change”, while elsewhere committing to an “annual review of industry association lobbying to monitor activity alignment with Sims’ policy and position (particularly regarding climate change)”. The disclosure also references a “Government Engagement & Advocacy Policy to guide activities” and outlines that the company “engag[es] through industry associations, business chambers, and directly with government where appropriate”, showing it considers both channels of influence. However, the company does not disclose the detailed outcomes of its reviews beyond stating “We did not find evidence of material misalignment”, nor does it outline escalation steps should future misalignments be identified, and the frequency of the association review appears inconsistent, which reduces transparency. Overall, the combination of a defined policy, named responsible executives, board-level oversight, and a systematic review of trade-association alignment indicates strong but not comprehensive governance of climate-related lobbying.
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B |