Sunway Bhd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Sunway Bhd does not disclose any specific governance process for its lobbying or climate lobbying activities. While it notes that "In 2020, Sunway Group set up a Board Sustainability Committee to oversee, assess and manage material matters that are ESG-related" and outlines efforts such as its internal carbon pricing framework—"Leading the industry, Sunway Group has forged ahead with introducing its own carbon pricing framework for its business divisions"—these initiatives relate to sustainability strategy, risk management, and emissions pricing rather than lobbying. The company states it has a public commitment to conduct engagement in line with the goals of the Paris Agreement—"Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […] Yes"—but provides no detail on how it governs, monitors, or aligns its direct or indirect lobbying with climate policy, nor does it name any individual or committee overseeing lobbying alignment. We found no evidence of any processes for reviewing or managing lobbying activities or any mechanisms to ensure climate lobbying is aligned with its policy positions. View Sources	E

Overall Assessment

Analysis

Score

None

Sunway Bhd does not disclose any specific governance process for its lobbying or climate lobbying activities. While it notes that "In 2020, Sunway Group set up a Board Sustainability Committee to oversee, assess and manage material matters that are ESG-related" and outlines efforts such as its internal carbon pricing framework—"Leading the industry, Sunway Group has forged ahead with introducing its own carbon pricing framework for its business divisions"—these initiatives relate to sustainability strategy, risk management, and emissions pricing rather than lobbying. The company states it has a public commitment to conduct engagement in line with the goals of the Paris Agreement—"Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […] Yes"—but provides no detail on how it governs, monitors, or aligns its direct or indirect lobbying with climate policy, nor does it name any individual or committee overseeing lobbying alignment. We found no evidence of any processes for reviewing or managing lobbying activities or any mechanisms to ensure climate lobbying is aligned with its policy positions.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Sunway Bhd offers only limited insight into its climate-policy lobbying. It identifies a single piece of regulation it has engaged with—the proposed amendments to Bursa Malaysia’s “Sustainability Reporting Framework” that form part of the Main Market Listing Requirements—but does not list any other laws or climate-related measures. The company discloses one mechanism and target for that engagement, noting that it “provided feedback on the proposed amendments … and was invited by Bursa Malaysia to participate,” yet it gives no detail on how that feedback was delivered or whether any other avenues, such as meetings or letters to government ministries, were used. Finally, the disclosure stops at broad aspirations such as aligning with TCFD recommendations and achieving net-zero emissions; it does not set out the specific changes it wanted incorporated into the Sustainability Reporting Framework or any other concrete policy outcomes. As a result, while Sunway does acknowledge a single lobbying interaction, the overall transparency of its climate-related lobbying activity remains limited.	D