Discovery Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Discovery Ltd has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company explicitly identifies several specific climate policies it has engaged with, including the "South Africa National Treasury's Draft National Green Finance Taxonomy," "South Africa Prudential Authority: Prudential Authority Climate Task Team (PACTT) – Climate Risk Indicators," "JSE Climate and Sustainability Disclosure Guidance," "International Sustainability Standards Board (ISSB) Exposure Drafts for Disclosure of Sustainability-related Financial Information and Climate-related Disclosures," "Climate Change Bill (South Africa)," "Pension Funds Act Regulation 28 amendments (infrastructure investments) to National Treasury," and "National Environmental Management: Waste Act." This level of detail ensures clarity about the policies engaged. The company also provides detailed information about its lobbying mechanisms and targets. It mentions participating in consultations "on policy and frameworks related to climate change and sustainability-related matters," providing comments "through the PRI collaboration platform," and responding "to the JSE's request for comments on its draft Climate Change and Sustainability Disclosure Guidance." Specific targets of its lobbying efforts are identified, including "South Africa National Treasury," "JSE," "Prudential Authority," and "financial sector regulators," demonstrating transparency in both the mechanisms and the entities targeted. Furthermore, Discovery Ltd has been transparent about the outcomes it seeks through its lobbying efforts. It aims to "strengthen disclosures of listed companies" through the JSE Climate and Sustainability Disclosure Guidance, improve "transparency and standards for disclosure" via the ISSB Exposure Drafts, and supports the National Green Finance Taxonomy, which "addresses climate change and other environmental priorities while simultaneously seeking to reduce social risks and enhance social impacts." Additionally, it seeks the "finalisation of draft indicators and the provision of further clarity and guidance from the PA that supports implementation," and has expressed its position on policies, such as "Support with minor exceptions," confirming alignment with the Paris Agreement. These statements clearly outline the desired policy changes and objectives, demonstrating a high level of transparency in its climate lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Discovery demonstrates strong governance in its climate lobbying alignment processes. The company has established oversight mechanisms through its Social and Ethics Committee, which "reviews Discovery's performance against its climate change strategy on a regular basis and reports back to the Discovery Board," ensuring accountability. Additionally, the Discovery Group Climate Change Steering Committee plays a role in monitoring and managing lobbying activities, as "any key advocacy engagements or engagement opportunities are shared with and tabled at this Steering Committee for consideration to ensure consistency with Group strategy and policy." The company also employs an "internal approval process in place for regulatory submissions (including those related to climate change matters for consultation) which ensures that any views put forward are consistent with Discovery's climate change strategy," further reinforcing its governance framework. The involvement of senior staff in industry forums and professional associations, along with the approval of memberships and participation, highlights efforts to align indirect lobbying activities with its climate strategy. While the evidence does not indicate a published lobbying audit or comprehensive review, the structured approach to monitoring and alignment, along with the identification of responsible parties, reflects strong governance.	3