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| Overall Assessment |
Comment |
Score |
| Comprehensive |
BHP Group Ltd has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has explicitly named specific climate policies it has engaged with, such as the Australian Government's Safeguard Mechanism reforms, the National Greenhouse and Energy Reporting (NGER) Scheme, and the Australian Sustainable Finance Taxonomy. It also highlights its advocacy for international policies, including the International Maritime Organisation's climate goals and the US Congress's clean energy investments. These disclosures provide clear identification of the policies and their jurisdictions. BHP has also been transparent about its lobbying mechanisms, detailing both direct and indirect engagement methods. Examples include submissions to government consultations, participation in industry roundtables, and discussions with senior decision-makers. The company identifies specific policymaking targets, such as the Australian Treasury, the Climate Change Authority, and international bodies like the ISSB and US SEC. Furthermore, BHP has clearly outlined the specific policy outcomes it seeks, such as transforming the Safeguard Mechanism into an emissions trading scheme, advocating for globally consistent climate-related disclosure standards, and supporting reforms to assist critical minerals producers. These disclosures reflect well-defined goals and desired changes in climate-related policies and regulations, demonstrating a high level of transparency in its lobbying efforts.
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4
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| Overall Assessment |
Comment |
Score |
| Comprehensive |
BHP demonstrates a comprehensive governance process for climate lobbying alignment, both direct and indirect, through detailed mechanisms, oversight structures, and accountability measures. The company explicitly states that "the Board has oversight of BHP's climate related lobbying approach," while "Senior management oversees the day to day implementation of climate change lobbying policies and practices." Furthermore, the 2023 industry association review was "overseen by the Chief Legal, Governance and External Affairs Officer," with detailed work led by various internal teams, including "Group Corporate Affairs, ESG, Group Governance and Sustainability and Climate Change teams." This indicates clear identification of responsible parties. BHP has published its "2023 industry association review report," which outlines findings and outcomes of its review process, demonstrating transparency and accountability. The review methodology includes assessing advocacy alignment along a continuum and providing "a comprehensive overview of the climate policy advocacy of our material association memberships." The company also commissioned "an external party (KPMG) to collect publicly available information on the associations' advocacy," showcasing robust monitoring mechanisms. The company commits to conducting both direct and indirect advocacy "consistent with the goals of the Paris Agreement," and uses its "Climate Policy Principles" to guide its own advocacy and influence the advocacy of industry associations. BHP monitors "in real time the advocacy of our material association memberships" and regularly reviews their climate policy advocacy against its principles, publishing findings on its website. Additionally, BHP has a structured process for addressing misalignment, including engaging with associations to seek changes in advocacy, publicizing misalignments, imposing conditions on membership, or suspending/ceasing membership if necessary. The governance process is further enhanced by the company's engagement with investors and stakeholders, which led to improvements in its industry association review methodology and increased review frequency to every two years. This indicates a proactive approach to ensuring alignment and transparency in climate lobbying governance.
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4
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