SPAR Group Ltd/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	SPAR Group discloses a substantial amount of detail about its climate-related lobbying. It explicitly identifies the policy instruments it engages on, including the “National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)” and the accompanying “Regulations and Notices Regarding Extended Producer Responsibility, 2020,” situating both within South Africa’s circular-economy framework. The company also describes how it lobbies and whom it targets, citing “participation in the South African Plastics Pact,” work through “forums such as stakeholder public feedback opportunities,” and involvement via the “National Business Initiative (NBI) coordinating work on this for its member organisations,” all of which bring it into dialogue with the “Department of Environment, Forestry and Fisheries, the Producer Responsibility Organisations, and other SA Plastics Pact members.” Finally, SPAR is clear about what it hopes to achieve, aiming for “70% of plastic packaging effectively recycled” and seeking to encourage “design for recycling and the incorporation of post-consumer recycled content in plastic packaging.” By naming concrete policy targets, detailing its engagement channels and audiences, and articulating measurable outcomes, the company demonstrates a strong level of transparency around its climate-related lobbying activities.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	SPAR Group Ltd/The has established a formal governance process for its policy-influencing activities, noting that its “Social and Ethics Committee, responsible for climate policy and strategy, reviews activities and engagements that influence policy and checks their alignment to overall strategy.” Its Sustainability Commitment, “My SPAR, Our Tomorrow,” “provides further guidance on climate, energy, water, waste and emissions reductions strategic actions” and SPAR “ensures that the Group’s climate-related engagements contribute towards the achievement of the Group’s strategic outcomes and support the Group’s commitments of net-zero by 2050.” SPAR also affirms it has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” answering “Yes” to that question. However, while this demonstrates clear oversight by a formal committee and an articulated policy framework, the company does not disclose any specific procedures for managing both direct and indirect lobbying activities through trade associations, nor does it reference additional monitoring mechanisms or independent reviews, indicating gaps in its broader lobbying governance.	2