Santam Ltd – Lobbying Governance & Transparency

Sign up to access all our data and the evidence and analysis underlying our overall scores. Once you've created an account, we'll get in touch with further details:

Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Santam discloses some mechanisms that indicate the company considers how its policy-advocacy activities are overseen and kept consistent with corporate positions, but the description remains partial and largely embedded within broader stakeholder-management structures. The evidence shows that “the head of stakeholder relations reports material stakeholder issues to the social, ethics and sustainability (SES) committee” and that “the SES committee is responsible for ensuring group stakeholder relationships are managed effectively and in line with policy, governance codes and best practice,” demonstrating a formal body charged with supervising external engagement. In relation to indirect lobbying, the parent Group explains that “Sanlam Investments monitors the strategy direction of the Association for Savings and Investments (ASISA) and the South African Insurance Association (SAIA). If there are any divergences, they will be escalated to the Sanlam Investment Group Board level and subsequently reviewed by the Social, Ethics, and Sustainability Committee of the Sanlam Board,” which indicates a defined escalation process to address misalignment between trade-association positions and group strategy, including climate matters. The company also acknowledges that it “works with government agencies, private institutions, industry associations, and non-profit organisations” on climate-related policy topics, confirming that policy engagement occurs and is therefore subject to the aforementioned oversight structures. However, Santam does not disclose a dedicated climate-lobbying policy, does not set out specific procedures for reviewing its own direct lobbying positions, and publishes no climate-lobbying alignment report or independent audit; consequently, the scope, frequency, and criteria used to assess the consistency of its lobbying with climate goals remain unclear. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Santam discloses some mechanisms that indicate the company considers how its policy-advocacy activities are overseen and kept consistent with corporate positions, but the description remains partial and largely embedded within broader stakeholder-management structures. The evidence shows that “the head of stakeholder relations reports material stakeholder issues to the social, ethics and sustainability (SES) committee” and that “the SES committee is responsible for ensuring group stakeholder relationships are managed effectively and in line with policy, governance codes and best practice,” demonstrating a formal body charged with supervising external engagement. In relation to indirect lobbying, the parent Group explains that “Sanlam Investments monitors the strategy direction of the Association for Savings and Investments (ASISA) and the South African Insurance Association (SAIA). If there are any divergences, they will be escalated to the Sanlam Investment Group Board level and subsequently reviewed by the Social, Ethics, and Sustainability Committee of the Sanlam Board,” which indicates a defined escalation process to address misalignment between trade-association positions and group strategy, including climate matters. The company also acknowledges that it “works with government agencies, private institutions, industry associations, and non-profit organisations” on climate-related policy topics, confirming that policy engagement occurs and is therefore subject to the aforementioned oversight structures. However, Santam does not disclose a dedicated climate-lobbying policy, does not set out specific procedures for reviewing its own direct lobbying positions, and publishes no climate-lobbying alignment report or independent audit; consequently, the scope, frequency, and criteria used to assess the consistency of its lobbying with climate goals remain unclear.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	The company provides only limited insight into its climate-related lobbying. It acknowledges engagement with policy processes such as South Africa’s Climate Change Bill and refers more broadly to frameworks like the Integrated Resource Plan, the Low-Emission Development Strategy and the Just Transition Framework, but it does not explain which provisions of these instruments it sought to influence or whether they were the sole focus of its advocacy. The description of how it lobbies is similarly high-level: it notes participation in industry bodies such as Business Unity South Africa and the South African Insurance Association, and partnerships with specific public entities including the eThekwini Municipality and the Department of Forestry, Fisheries and the Environment, yet it offers no detail on concrete mechanisms such as formal submissions, meetings, or correspondence. Finally, the company speaks in general terms about aims such as enhancing community resilience, supporting a just transition and aligning disclosures with global best practice, but it does not articulate the specific policy changes or measurable outcomes it is seeking through its lobbying. Overall, the disclosures show acknowledgement of climate-policy engagement but lack the specificity necessary to demonstrate strong transparency.	D