ASX Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate ASX Ltd offers a moderate degree of openness about its climate-policy advocacy. It names identifiable files on which it has engaged—most notably Treasury’s draft legislation for mandatory climate-related financial disclosure and the Federal Government’s reforms to the Safeguard Mechanism—and therefore allows readers to see which climate measures it tries to influence. The company also outlines its main routes of influence, indicating that it makes formal written submissions, holds “regular engagement with policymakers,” and approaches specific bodies such as Treasury, the Reserve Bank of Australia and the Clean Energy Regulator, with many of these submissions publicly available. Nevertheless, the description of what ASX hopes to achieve remains high-level. Statements such as a desire to “support Australia’s transition to a low-carbon economy,” to ensure reforms “operate as intended,” or that it is “currently preparing a submission on the scope of services to which the legislation will apply” do not translate into clear, measurable policy asks. As a result, while the company is reasonably straightforward about which policies it engages on and how it contacts decision-makers, it provides only limited detail on the specific outcomes it seeks from those lobbying activities. 2
Lobbying Governance
Overall Assessment Comment Score
None ASX Ltd’s disclosures focus extensively on climate-related risk management and sustainability oversight but make no mention of any governance processes for lobbying activities. For example, its board “establishes the purpose and strategic direction, oversees and approves risk management strategy and risk appetite and monitors progress against climate-related risks,” and the Sustainability Working Group, “chaired by the Chief Financial Officer,” is charged with coordinating “environmental, social and governance (ESG) issues relevant to ASX’s business.” While these quotes demonstrate detailed frameworks for identifying and mitigating climate risks, the company does not disclose any structures, policies, or responsible individuals dedicated to overseeing, monitoring or aligning its direct or indirect lobbying efforts with its climate policy goals. We found no evidence of a lobbying review process, board sign-off on lobbying positions, or oversight of trade-association activities, indicating that ASX Ltd does not disclose its approach to governing lobbying alignment. 0