Sun International Ltd/South Africa

Lobbying Governance & Transparency

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Lobbying Governance
Overall Assessment Analysis Score
Moderate Sun International provides some insight into how it governs climate-related advocacy, indicating a level of internal oversight but without the depth of a full alignment framework. The company states that "All activities are overseen by the Group ESG Manager to ensure compliance with existing partnerships across the group" and that "On an annual basis the group reviews all its activities and processes … The risks are then aligned to legal requirements and pending policy decisions. Any changes to our direct and indirect activities are included in annual strategy and planning sessions," which together describe a recurring process for checking that engagement activities match its climate strategy. Oversight responsibility is clearly assigned, as "the group ESG manager reports directly, with the support of the CE, to the social and ethics committee and the risk committee," and the ESG manager also "attends these meetings and provides feedback to the committee based on the relevant issues affecting the business." This indicates that both a named individual and formal board-level committees receive regular information on climate-related engagement. However, the disclosures do not explain how the company evaluates or corrects the climate positions of trade associations, nor do they provide a public lobbying-alignment report or detail specific criteria for assessing direct versus indirect advocacy. Consequently, while there is evidence of a policy and oversight structure, the company does not disclose a comprehensive mechanism for monitoring the consistency of its lobbying across all channels or for addressing misalignment, suggesting only moderate governance in this area.

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C
Lobbying Transparency
Overall Assessment Analysis Score
None Sun International provides no disclosure of any engagement aimed at influencing climate-related public policy. The company only notes that it comments on proposed amendments to legislation affecting the casino and bookmaking industries, without mentioning any climate or energy transition measures, naming any specific bills, identifying policymakers, describing lobbying channels, or stating the policy changes it seeks. As a result, we found no evidence of transparency around climate lobbying activities.

E