AEM Holdings Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	AEM Holdings discloses a robust sustainability governance framework but does not disclose any specific processes or oversight for lobbying or policy engagement. The evidence shows that “the strategic direction for the Company’s sustainability efforts is led by the Board of Directors” and that the Audit and Risk Management Committee “oversees the identification, management, and monitoring of material ESG factors, including the oversight of climate related risks and opportunities,” yet there is no reference to any policy, committee, or individual responsible for aligning direct or indirect lobbying activities with the company’s goals. When asked if it has a position statement to conduct engagement in line with the Paris Agreement, AEM responded “No, and we do not plan to have one in the next two years,” further confirming that the company does not disclose any governance of its lobbying efforts. View Sources	E

Overall Assessment

Analysis

Score

None

AEM Holdings discloses a robust sustainability governance framework but does not disclose any specific processes or oversight for lobbying or policy engagement. The evidence shows that “the strategic direction for the Company’s sustainability efforts is led by the Board of Directors” and that the Audit and Risk Management Committee “oversees the identification, management, and monitoring of material ESG factors, including the oversight of climate related risks and opportunities,” yet there is no reference to any policy, committee, or individual responsible for aligning direct or indirect lobbying activities with the company’s goals. When asked if it has a position statement to conduct engagement in line with the Paris Agreement, AEM responded “No, and we do not plan to have one in the next two years,” further confirming that the company does not disclose any governance of its lobbying efforts.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	AEM Holdings Ltd provides only limited insight into its climate-related lobbying. Its disclosure names general methods – it says it takes part in “participation in government initiatives, policy working group, attend conferences/seminars held by the relevant authorities, reporting and surveys and submitting its comments in public consultations (if necessary)” – which confirms that the company sometimes engages directly with regulatory processes, but it does not identify which governments, agencies or legislative fora it approaches. The company does not cite any specific climate or energy policies it has tried to influence, nor does it explain the positions it advocates or the policy outcomes it seeks. As a result, stakeholders are told that some engagement occurs but are given virtually no detail about the policy focus, targets or objectives of that engagement, reflecting a low level of transparency overall.	D