BHP Group Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	BHP discloses a comprehensive and publicly documented governance system for climate-related lobbying. The company notes that The Board has oversight of BHPs climate related lobbying approach and that its 2023 industry-association review was overseen by the Chief Legal, Governance and External Affairs Officer and approved by the BHP Board, establishing clear senior accountability. A formal policy covers both channels of influence: We commit to conducting our advocacy consistent with the goals of the Paris Agreement in both our direct advocacy and our indirect advocacy within industry associations and We use our Climate Policy Principles to inform and guide our own advocacy (our direct advocacy) and to influence the advocacy of the industry associations of which we are a member. For indirect lobbying, BHP operates a recurring, publicly available audit: We published our first industry association review in 2017 repeated this process in 2018 and 2019, with the most recent cycle stating that our 2023 industry association review report was approved by the BHP Board after data collection by an external party (KPMG). These reviews identify material differences between BHP and our member associations on climate change policy and the company undertake[s] regular monitoring and take[s] action to exit or suspend membership when necessary, citing its engagement that prompted the US Chamber of Commerce to revise its stance on carbon pricing. Governance controls begin before any lobbying occurs: approvals are required before joining an industry association each prospective association is subject to due diligence and compliance checks and a review of policy alignment, with renewals every two years, and BHP monitor[s] in real time the advocacy of our material association memberships while pledging to disclose in real time if we determine that one of our member associations has substantially departed from our Global Climate Policy Standards. By combining board-level oversight, a defined management process for both direct and indirect advocacy, routine public alignment reviews supported by an external adviser, and transparent corrective mechanisms, BHP demonstrates strong, transparent and proactive governance of its climate-lobbying activities, though its published audits focus more heavily on industry-association activities than on a systematic review of direct lobbying positions. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

BHP discloses a comprehensive and publicly documented governance system for climate-related lobbying. The company notes that The Board has oversight of BHPs climate related lobbying approach and that its 2023 industry-association review was overseen by the Chief Legal, Governance and External Affairs Officer and approved by the BHP Board, establishing clear senior accountability. A formal policy covers both channels of influence: We commit to conducting our advocacy consistent with the goals of the Paris Agreement in both our direct advocacy and our indirect advocacy within industry associations and We use our Climate Policy Principles to inform and guide our own advocacy (our direct advocacy) and to influence the advocacy of the industry associations of which we are a member. For indirect lobbying, BHP operates a recurring, publicly available audit: We published our first industry association review in 2017 repeated this process in 2018 and 2019, with the most recent cycle stating that our 2023 industry association review report was approved by the BHP Board after data collection by an external party (KPMG). These reviews identify material differences between BHP and our member associations on climate change policy and the company undertake[s] regular monitoring and take[s] action to exit or suspend membership when necessary, citing its engagement that prompted the US Chamber of Commerce to revise its stance on carbon pricing. Governance controls begin before any lobbying occurs: approvals are required before joining an industry association each prospective association is subject to due diligence and compliance checks and a review of policy alignment, with renewals every two years, and BHP monitor[s] in real time the advocacy of our material association memberships while pledging to disclose in real time if we determine that one of our member associations has substantially departed from our Global Climate Policy Standards. By combining board-level oversight, a defined management process for both direct and indirect advocacy, routine public alignment reviews supported by an external adviser, and transparent corrective mechanisms, BHP demonstrates strong, transparent and proactive governance of its climate-lobbying activities, though its published audits focus more heavily on industry-association activities than on a systematic review of direct lobbying positions.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	BHP Group Ltd discloses its climate-policy lobbying in considerable depth. It names a wide range of specific measures it has engaged on, including Australia’s “Safeguard Mechanism”, proposed amendments to the “National Greenhouse and Energy Reporting (NGER) Scheme”, the “Australian Sustainable Finance Strategy” and associated climate-related financial-disclosure legislation, consultations on the “Draft South Australia Hydrogen and Renewable Energy Act”, and international proposals such as the US SEC climate-disclosure rule and elements of the US “Build Back Better” agenda. The company is equally explicit about how and where it lobbies: it describes “lodging submissions, appearing before inquiries, meeting with officials, commissioning research, issuing media releases, responding to media queries, and commissioning advertising”, and cites targets that include the Australian Treasury’s Climate & Energy Division, the Department of Climate Change, Energy, the Environment and Water, the Climate Disclosure Unit, the US SEC and ISSB, as well as indirect engagement through industry bodies in Australia, Canada, Chile and the United States. Finally, BHP sets out the concrete outcomes it seeks, advocating for “transforming the Safeguard Mechanism into an emissions trading scheme”, calling for the “removal of unnecessary restrictions on new sources of energy supply such as existing prohibitions on nuclear energy”, urging a change so that “the first sustainability report would be required for annual reporting periods starting on or after 1 January 2025”, pressing for alignment of Australian requirements with ISSB standards, and encouraging the government “to cover a greater proportion of the economy in the Safeguard Mechanism” to enable a unified carbon market. These detailed disclosures on the policies addressed, the mechanisms and targets of engagement, and the specific legislative or regulatory changes sought demonstrate a high level of transparency in BHP’s climate-related lobbying.	A