Aspen Pharmacare Holdings Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Aspen Pharmacare Holdings Ltd demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate change. The company states that "Aspen’s direct and indirect business activities and stakeholder engagement processes are aligned to the Group’s strategic objectives," and this alignment is monitored by the Social & Ethics Committee and the Aspen Board. The Group Risk and Sustainability Department, under the direction of the Group Chief Operations Officer, is tasked with developing and promoting environmental management principles and standards, while the Group Ethics & Compliance Department ensures consistency across operations. Formal structures such as "Centres of Excellence" have been established to drive climate change ambitions, with mandates to set and track measurable targets aligned with the UN Sustainable Development Goals. Additionally, facilities engage with regional stakeholders and policymakers, such as the EU emissions trading system and the Australian Environment Business Network. A combined assurance audit plan is in place to monitor alignment of environmental policies and systems, with progress overseen by the Group Risk and Sustainability Department, site management teams, Group Executives, and the Social & Ethics Committee. However, while these mechanisms indicate a structured approach to sustainability and climate-related activities, the company does not disclose a specific governance process explicitly dedicated to ensuring alignment of lobbying activities with climate goals. Furthermore, Aspen acknowledges that it does not yet have a public commitment to conduct engagement activities in line with the Paris Agreement, although it plans to establish one within two years. The evidence suggests that while there are processes for monitoring and aligning broader sustainability efforts, the governance framework for lobbying, particularly climate-related lobbying, lacks detailed mechanisms and oversight specific to this area. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Aspen Pharmacare Holdings Ltd demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate change. The company states that "Aspen’s direct and indirect business activities and stakeholder engagement processes are aligned to the Group’s strategic objectives," and this alignment is monitored by the Social & Ethics Committee and the Aspen Board. The Group Risk and Sustainability Department, under the direction of the Group Chief Operations Officer, is tasked with developing and promoting environmental management principles and standards, while the Group Ethics & Compliance Department ensures consistency across operations. Formal structures such as "Centres of Excellence" have been established to drive climate change ambitions, with mandates to set and track measurable targets aligned with the UN Sustainable Development Goals. Additionally, facilities engage with regional stakeholders and policymakers, such as the EU emissions trading system and the Australian Environment Business Network. A combined assurance audit plan is in place to monitor alignment of environmental policies and systems, with progress overseen by the Group Risk and Sustainability Department, site management teams, Group Executives, and the Social & Ethics Committee. However, while these mechanisms indicate a structured approach to sustainability and climate-related activities, the company does not disclose a specific governance process explicitly dedicated to ensuring alignment of lobbying activities with climate goals. Furthermore, Aspen acknowledges that it does not yet have a public commitment to conduct engagement activities in line with the Paris Agreement, although it plans to establish one within two years. The evidence suggests that while there are processes for monitoring and aligning broader sustainability efforts, the governance framework for lobbying, particularly climate-related lobbying, lacks detailed mechanisms and oversight specific to this area.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Aspen Pharmacare Holdings Ltd. provides only limited insight into its climate-related lobbying. The company signals that it engages on “energy pricing and policy matters” and broader climate legislation in South Africa through industry bodies such as Business Unity South Africa and the National Business Initiative, but it does not identify any specific laws, regulations or bill numbers it has tried to influence. Its description of lobbying channels is confined to indirect participation via those trade associations; it gives no detail on concrete mechanisms like written submissions, meetings or consultations, nor does it name the government departments or officials that are the focus of these efforts. Likewise, Aspen offers only broad statements of intent—support for a “transition to a lower-carbon economy,” affordable energy and climate-adaptation measures—without spelling out the precise policy changes or measurable outcomes it is advocating. This high-level narrative indicates some engagement, yet leaves stakeholders without clear visibility of which policies are being targeted, how influence is exerted or what specific results the company is seeking.	D