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Boursa Kuwait Securities Co KPSC presents no disclosures of an internal framework to govern its lobbying activities. While the company reports that it “engaged in lobbying efforts with regulatory bodies at the Group and operational levels,” it does not describe any process or policy to ensure that these efforts align with its climate objectives. The evidence instead focuses on climate governance structures, citing the “Climate Change Compliance Framework approved by the Board of Directors” and the cross-disciplinary CAC, which “provides the Board with an oversight on climate-related matters” and meets quarterly. Similarly, the establishment of an ESG Committee chaired by an independent board member is detailed, with responsibilities such as “ESG Strategy,” “Policy Framework,” and “Reporting,” yet there is no reference to reviewing or managing lobbying activities. We found no evidence of a specific individual or formal body tasked with reviewing or approving lobbying positions, nor any criteria for aligning direct or indirect lobbying with the company’s climate or ESG policies.
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