BHP Group Ltd

We commit to conducting all our advocacy efforts consistent with our Climate Policy Principles, and to use our Climate Policy Principles to direct the advocacy of the industry associations of which we are a member.

Achieving the Paris Agreement goals will require supportive policy across jurisdictions globally. The following principles underpin our views on how governments should take action on climate change: [...] We engage on policy matters directly with government and through our membership of industry associations and issue specific coalitions and initiatives. Key examples of our recent public advocacy include: [...] We recognise there is considerable stakeholder interest in the role played by industry associations in public policy debates, particularly in the context of climate change policy. Over the past five years, we have introduced a range of measures to strengthen governance of our member associations and their climate change advocacy. These have included: - Establishing a transparent process to review the alignment between BHP's climate policy positions and those held by our member associations, and to act where 'material differences' have been identified - Publishing our Global Climate Policy Standards, which set our expectations for how member associations should advocate on climate policy - Committing to disclose in 'real time' if we determine that one of our member associations has substantially departed from our Global Climate Policy Standards - Working with key member associations in Australia to clarify advocacy roles and responsibilities and improve the transparency of their advocacy activities - Disclosing key information about BHP's material member associations, including membership fees and our rationale for membership[85] BHP has also been taking proactive steps to enhance the climate advocacy of our member associations. This has involved: - Working with other members to progress the Mineral Council of Australia's (MCA) Climate Action Plan. This plan is focused on developing technology pathways to drive emissions reduction, improving the sector's understanding and management of climate change risks, and raising awareness of the sector's response to climate change. - Working with the Australian Petroleum Production and Exploration Association to update its climate change policy principles. These provide explicit support for achieving net zero emissions by 2050, and are aligned with BHP's Global Climate Policy Standards. - Supporting the efforts of the C2ES, the CEO Climate Dialogue and the Climate Leadership Council to provide public backing for the enactment of enact ambitious climate policy in the United States Congress. - Contributing to the development of the Business Council of Australia's new National Climate Strategy, which is expected to be released ahead of the 26[th] United Nations Climate Change Conference of the Parties (COP26) in late 2021. We are also strengthening our approach by subjecting our material member associations to a formal industry association review, as we announced in 2020. In accordance with BHP's principles for participating in industry associations, if the review process identifies a material difference with a member association on climate policy, BHP will consider a range of remediation measures, including suspension or cessation of membership. BHP's general view, however, is that there is greater scope to achieve positive climate outcomes if we use our influence within industry associations. As an example of this, BHP's 2019 industry association review identified two material differences with the US Chamber of Commerce (US Chamber), relating to the association's previous opposition to specific emissions reduction targets and carbon pricing. Through engagement from BHP and other member companies, the US Chamber recently updated its climate change position statement to provide support for market-based approaches to accelerate emissions reduction across the US economy. The US Chamber also recently welcomed the return of the United States 'to international leadership on climate change' following the announcement of President Biden's new climate goal. BHP will continue to use its position on the US Chamber's Task Force on Climate Action to further strengthen the association's advocacy on climate policy, particularly in regard to providing clearer support for carbon pricing and emissions reduction targets aligned with the Paris Agreement goals. The next update to this review will be published in 2022. Further information on our approach to industry associations is available at bhp.com/our-approach/operating-with-integrity.

We commit to conducting our advocacy consistent with the goals of the Paris Agreement in both our direct advocacy across all our operating jurisdictions (including through our subsidiaries) and our indirect advocacy (including lobbying) within industry associations of which we are a member. [...] 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 (our 'indirect advocacy'). [...] We keep our Climate Policy Principles under review and make updates where necessary.

BHP has a robust process for reviewing its membership of industry associations, specifically regarding assessment of an association's advocacy against our Global Climate Policy Standards. The process is continually reviewed and strengthened when appropriate enhancements are identified. We undertake regular monitoring and take action to exit or suspend membership when necessary. [...] BHP's governance of its industry associations forms a core part of its strategic climate agenda. Further details of our approach are contained in section 6 of the Climate Transition Action Plan. Shareholders have the opportunity to consider the Climate Transition Action Plan at Item 20 and the Board considers that the Plan and Item 20 address the primary concerns raised by the shareholders requisitioning this resolution. [...] Over the past five years, BHP has introduced a range of measures to strengthen BHP's governance of its member associations and their climate change advocacy. These include: – publishing BHP's Global Climate Policy Standards[(1)], which set the Group's expectations for how member associations should advocate on climate policy. These standards include having an explicit position supporting the goals of the Paris Agreement and the setting of emissions reduction targets aligned with these goals – establishing a transparent process to review the alignment between BHP's climate policy positions and those held by the Group's member associations, and to act (such as cessation or suspension of the Company's membership) where 'material differences' have been identified – committing to disclose in 'real time' if BHP determines that one of the Group's member associations has substantially departed from the Global Climate Policy Standards – working with key member associations in Australia to clarify advocacy roles and responsibilities and improve the transparency of their advocacy activities – disclosing key information about BHP's material member associations, including membership fees and the Group's rationale for membership[(2)]

* Our governance arrangements

It is a requirement under BHP's mandatory minimum performance requirements for external engagement that approvals are required before joining an industry association. As part of the approvals process, each prospective association is subject to due diligence and compliance checks and a review of policy alignment. We also consider whether our membership of the association is necessary, relative to our existing memberships and the proposed membership fee. The approval process is renewed every two years.

The Board has oversight of BHP's climate related lobbying approach. Senior management oversees the day to day implementation of climate change lobbying policies and practices.

In line with BHP's prior practice, our 2023 industry association review report was approved by the BHP Board. Our 2023 industry association review was overseen by the Chief Legal, Governance and External Affairs Officer. Detailed work was led by Group Corporate Affairs, with the assistance of our ESG, Group Governance and Sustainability and Climate Change teams. We commissioned an external party (KPMG) to collect publicly available information on the associations' advocacy (e.g., from association websites, government consultation processes, news reports and social media)." [...] "* Our approach to indirect advocacy

Our approach to indirect advocacy on climate policy comprises four main elements:

+ We clearly communicate to industry associations (via our global Climate Policy Principles) our views on how governments can best pursue the aims of the Paris Agreement.
+ We use our positions on industry association boards, committees and working groups to seek to influence the climate policy advocacy of the relevant associations.
+ We monitor in real time the advocacy of our material association memberships – to give us the best opportunity to address any potential misalignments as soon as they occur.
+ We regularly review the climate policy advocacy of our material association memberships against our global Climate Policy Principles and publish the findings of these reviews on our website (see below for more detail)." [...] "* Our industry association review process

Our industry association reviews provide us a structured and transparent means of assessing the climate policy advocacy of our material association memberships and acting on potential areas of misalignment.

We published our first industry association review in 2017. We repeated this process (with some modification) in 2018 and 2019. In 2020, as part of a broader suite of changes, we shifted our industry association review process from an annual to a three-yearly cycle.

Following recent engagement with investors and other stakeholders, we have decided to increase the frequency of our industry association reviews to every two years. In the intervening years, we will publish an update on the progress we have made in addressing areas of misalignment from the prior year review and any relevant findings from our real time monitoring.

And finally, we participated in a number of initiatives that help shape policy, ranked highly in several investor benchmarks, and progressed our regular industry association review, which will be published by the end of December 2022. [...] Achieving the aims of the Paris Agreement will require supportive policy across jurisdictions globally. The policymaking process is complex, and change is unlikely to be smooth or linear. [...] We believe BHP can best support policy development by ensuring we meet our own climate targets, goals and strategies, continuing to make the case for the economic opportunities arising from the energy transition, and focusing on those policy areas where we are likely to have the greatest ability to influence change.

In addition to our public policy engagement, our climate change strategy is supported by active engagement with a wide variety of stakeholders, including investors, peer companies and non-governmental organisations. We regularly hold one-on-one and group meetings with investors and their advisers. We also seek input and insight from external experts, such as the BHP Forum on Corporate Responsibility (FCR), which is composed of civil society leaders and BHP executives and has played a critical role in the development of our position on climate change. [...] We published our first industry association review in 2017 to identify 'material differences' between BHP and our member associations on climate change policy, repeating the exercise in 2018. In 2019, we broadened our methodology to capture additional organisations and assess the extent of overall alignment between BHP and our association memberships on climate change policy. Outcomes from our 2019 review are set out in our 2019 Industry Association Review Report available online at bhp.com. [...] Following our 2019 review, we commenced a process to understand how we could further enhance our overall approach to industry associations to ensure we maximise the value of our memberships. We have also taken further steps to address investor expectations around climate change advocacy by industry associations by engaging with a broad range of stakeholders from around the world, including investors, civil society groups, community groups and industry associations. As a result of that feedback, we decided to make the following key changes to our approach to industry associations: - We developed and published our Global Climate Policy Standards - We announced our intention to work with the various associations that represent the minerals sector in Australia to develop and agree a protocol for the allocation of advocacy accountabilities at national and state levels - We announced our intention to work with key associations in Australia to develop and publish an annual advocacy plan - We made a number of enhancements to our own disclosure of our industry association memberships. We will conduct and publish our next formal industry association review in 2022.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Our Code of Conduct (Our Code) is based on Our Charter values and sets the minimum expectations on how we engage with both internal and external stakeholders, including governments. Our position on climate change is directly supported by Our Charter value of Sustainability and supporting Our Requirements standards (which define mandatory minimum performance requirements for all our operated assets). In particular, we prescribe standards of engagement with government, media, employees, equity analysts, investors and host communities. We published our first industry association review in 2017 to identify 'material differences' between BHP and our member associations on climate change policy, repeating the exercise in 2018. In 2019, we broadened our methodology to capture additional organisations and assess the extent of overall alignment between BHP and our association memberships on climate change policy. Outcomes from our 2019 review are set out in our 2019 Industry Association Review Report available online at bhp.com. Following our 2019 review, we commenced a process to understand how we could further enhance our overall approach to industry associations to ensure we maximise the value of our memberships. We have also taken further steps to address investor expectations around climate change advocacy by industry associations by engaging with a broad range of stakeholders from around the world, including investors, civil society groups, community groups and industry associations. As a result of that feedback, we decided to make the following key changes to our approach to industry associations:

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

Industry Association Review

June 2023

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Contents

Executive Summary 3 Our approach 4 Findings and outcomes 5 Appendix A 6

Disclaimer and limitations

Objectivity

The views and conclusions expressed in this Report are those of BHP. No association was consulted on BHP's approach or provided with BHP's assessment or proposed outcomes prior to finalisation of this Report. BHP has sought (with KPMG's input) to provide a balanced and fair summary of the policy and advocacy positions of each association included in the scope of our review, but we recognise that the nature of a review of policy and advocacy positions in any area of public debate necessarily involves interpretation, judgement and opinion.

We have also not undertaken any verification of the public information regarding any of the associations referred to in this Report and BHP makes no representation regarding the accuracy of any such information, including the information regarding their advocacy positions as contained in Appendix A.

Evidence-based review

The review is based on publicly available information. The review could not, and therefore did not, encompass or take into account information which may have been discussed 'behind closed doors', or subsequently amended after the review period. BHP did not separately verify the publicly available information on which the review was based.

Executive Summary

The purpose of this Report is to provide the outcomes of our review of policy alignment between BHP and our material association memberships in relation to climate change.

We join, and remain members of, industry associations that we believe can help achieve better outcomes on public policy, practice and/or standards.

We also believe that we can have a positive impact on standards and advocacy working with and within industry associations.

Our 2023 industry association review focused on 15 association memberships we consider to be material. Of these, we found: • 10 were aligned with our August 2020 Global Climate Policy Standards.

• Five had some, non-material misalignment: the Canadian Chamber of Commerce (CCC), Minerals Council of Australia (MCA), New South Wales Minerals Council (NSWMC), Queensland Resources Council (QRC) and United States Chamber of Commerce (US Chamber). In relation to: – CCC, MCA and US Chamber, our view is that we derive sufficient benefit from our membership of these associations. Accordingly, and consistent with our principles for participating in industry associations, we have determined to remain a member of the CCC, MCA and US Chamber, while actively encouraging these associations to address the identified areas of misalignment.

– NSWMC, we will remain a member conditional on the association confirming its policy agenda to support the achievement of a reliable, affordable and zero emissions electricity grid.

– QRC, we have decided to resume full membership given that the reason for our suspension in October 2020 has been resolved and given the benefits derived from membership. We will also encourage the association to address the area of misalignment identified by this review.

• None had material misalignment with our August 2020 Global Climate Policy Standards.

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Future action

In February 2023, we engaged with investors and other stakeholders on possible further improvements we could make to our industry association review approach. Based on the feedback we received, we will be increasing the frequency of our industry association reviews to every two years. In the intervening years, we will publish (as relevant) an update on the progress we have made in addressing identified areas of misalignment and any relevant findings from our real time monitoring.

Governance

This Report has been approved by the BHP Board.

Our approach

Scope of the review

Our 2023 industry association review considered the climate policy advocacy of in-scope associations in the period January 2020 to February 2023. Fifteen industry associations (see Appendix A) were in scope for the review on the basis that they met at least one of the following two 'materiality' criteria as at July 2022: • our base membership fee in 2022 was equal to or greater than US$100,000; and/or • there is significant stakeholder interest in the advocacy of the association (as determined by whether the association was listed on InfluenceMap's ranking of industry associations).

Methodology

Assessing alignment and acting on material misalignment

We used the following three-step approach to assess the climate policy advocacy of our material associations: • We commissioned an external party (KPMG) to collect publicly available information on the associations' advocacy (e.g., from association websites, government consultation processes, news reports and social media).

• We assessed the extent to which the advocacy aligned with our August 2020 Global Climate Policy Standards. This assessment considered both the formal position statements of industry associations and their day-to-day advocacy, and focused primarily on advocacy of direct relevance to the mining sector. In determining whether an identified misalignment was material or not, we considered: – the nature of the identified misalignment (e.g., does it relate to a fundamental difference over principle or outcomes? Or is it more of a practical disagreement over the best way to achieve a shared goal?); – the nature of the relevant policy issue (e.g., how crucial is the issue in terms of enabling the achievement of the aims of the Paris Agreement?); and – the consistency and trajectory of association advocacy (e.g., does the identified misalignment fit within a broader pattern of association advocacy, or does it appear to be more of a one-off? Has the advocacy of the association in relation to the identified misalignment improved over time?).

• For those industry associations that were found to have some, non-material, misalignment, we made a determination of what actions we would take to address the identified misalignment (having regard to BHP's principles for participating in industry associations).

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Position on the Paris Agreement

One of our guiding principles for participating in industry associations is that the policy advocacy of an industry association should reflect the views of its membership. On issues where no broad industry consensus exists, we believe associations should refrain from advocacy.

As a consequence, we generally do not view the absence of an association position on an element of our August 2020 Global Climate Policy Standards as representing, by itself, sufficient evidence that a misalignment exists (given such 'silence' could reflect a lack of consensus amongst the association's membership).

The only exception relates to the Paris Agreement. Given the centrality of the Paris Agreement to the global effort to address climate change, we consider the absence of a position on the Paris Agreement to represent a material misalignment.

Findings and outcomes

Alignment

Applying the methodology outlined above, we found that, of the 15 material industry associations, there was: • alignment with 10 industry associations; • some, non-material misalignment with five industry associations, being CCC, MCA, NSWMC, QRC and the US Chamber; and • no material misalignment.

Appendix A provides further detail on our findings.

Actions on non-material misalignment

In determining what actions to take regarding our membership of the five associations where there was non-material misalignment, we have been guided by the nature of the misalignment and the benefits of membership.

Given these factors, we have decided to remain members of the CCC and MCA. We will actively encourage these associations to address the areas of misalignment identified.

In relation to the US Chamber, our 2019 industry association review found two material differences (relating to greenhouse gas (GHG) emissions reduction targets and carbon pricing). The US Chamber has largely addressed these differences by committing to work with the Biden Administration in pursuit of its new 2030 emissions reduction target, and by publicly shifting its posture in favour of carbon pricing. Given this, and our view of the benefits of membership, we will remain a member and actively encourage the US Chamber to address areas of misalignment.

In relation to the NSWMC, our 2019 industry association review found one material difference (relating to balancing the energy trilemma). Given there is some similarity between this material difference and one of the areas of misalignment found as part of our 2023 review, and our view that we derive benefit from our membership of NSWMC, we have determined that we will remain a member of NSWMC, although our ongoing membership is subject to the association confirming its policy agenda to support the achievement of a reliable, affordable and zero emissions electricity grid.

Queensland Resources Council

We suspended our membership of the QRC in October 2020. This followed a decision by the QRC to undertake advertising that specifically targeted the overall standing of one political party during the 2020 Queensland election campaign.

As part of our 2023 industry association review, we considered: • The QRC's adherence to the Political Engagement Policy adopted by the QRC Board in February 2021. Based on our review of the QRC's public commentary (including media releases, interviews and social media activity) from February 2021 to February 2023, it is our view that the QRC has adhered to its Political Engagement Policy.

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• Advocacy alignment. As we note above, our 2023 industry association review found that there is some, non-material, misalignment between the climate policy advocacy of the QRC and BHP's August 2020 Global Climate Policy Standards. The identified area of misalignment related to one media release issued by the QRC and does not appear to form part of a broader pattern of advocacy.

• The benefits of QRC membership. The key drivers of the value QRC offers include: – Providing a consolidated industry voice to the Queensland Government on matters of significance to the mining sector. In the past, this has included coordinating how the sector and government could protect workers and the community during the COVID-19 pandemic. More recently, the QRC has played a key role in advocating against the Queensland Government's increase in royalty rates that threaten the State's attractiveness as an investment destination, and engaging with the Queensland Government on the sector's ongoing commitment to address sexual assault and sexual harassment in its workforce.

– Promoting the positive contribution that the mining sector makes to Queensland, in terms of direct and indirect employment, procurement spend and payments to government. The QRC produces an annual economic report, which underpins its promotional efforts in this regard.

– Supporting improved inclusion and diversity practices in the Queensland mining sector. Most notably, the QRC highlights and celebrates best practice through its QRC Indigenous Awards and Women in Mining and Resources Queensland.

– Addressing the skills crisis facing the mining sector. The QRC manages a partnership with the Queensland Government (the Queensland Minerals and Energy Academy) that seeks to put 'students onto pathways into the resources sector and other science, technology, engineering and maths (STEM) industries'.

– Driving sector performance through its various technical working groups. In the past, we found these working groups provided a cost-effective means of staying up-to-date on potential legislative/regulatory changes, as well as industry best practice.

Based on the above, we have determined to remove suspension of our membership effective 1 July 2023.

Appendix A – Summary of association advocacy

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Appendix A – Summary of association advocacy continued

Australian Industry Greenhouse Network

We have found there to be alignment between the climate policy advocacy of the Australian industry Greenhouse Network (AIGN) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A network of ~20 Australian-based industry associations and corporations that see value in joint action on climate change to promote sustainable industry development.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements AIGN's formal principles emphasise the significance of global action and the need for global agreement. AIGN has reflected these principles in its advocacy.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

AIGN has repeatedly expressed support for the aims of the Paris Agreement and has referred to these aims in setting the parameters of its advocacy.

AIGN has expressed support for the Australian Government's emissions reduction targets and proposal to update these targets every five years.

AIGN's formal principles are focused on the delivery of 'least cost, environmentally effective and equitable outcomes for Australia'. In line with these principles, AIGN has: engaged on the proposed reform of the Safeguard Mechanism; supported measures that accelerate the development of pre-commercial technology and nationally consistent policy approaches; and advocated in favour of allowing 'access to genuine international units'.

Pre-commercial technology

Enabling the broader transition

AIGN's formal principles emphasise the important role government can play in unlocking 'first-of-a-kind' technologies. AIGN has reflected these principles in its advocacy.

AIGN has advocated in favour of integrated and transparent policy frameworks, the importance of taking into account different abatement capabilities between and within countries, and the pursuit of equitable outcomes.

Guiding principles

Balanced

Fact-based

AIGN's advocacy appears to be balanced between upholding business competitiveness and highlighting the upside presented by the energy transition.

AIGN's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused AIGN generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions. For example, AIGN previously expressed support for the use of Kyoto carryover credits, but does not appear to have done so during the review period.

Technology neutral AIGN generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Business Council of Australia

We have found there to be alignment between the climate policy advocacy of the Business Council of Australia (BCA) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and multi-sector industry association. It has approximately 130 members.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements BCA has advocated in favour of international climate cooperation, the Paris Agreement and Australia making a fair contribution to global efforts.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

BCA has expressed support for the aims of the Paris Agreement and has proposed a policy agenda focused on achieving these aims.

BCA has advocated in favour of net zero by 2050, increasing the ambition of Australia's 2030 target, and the Australian Government's new Climate Change Act.

BCA has advocated in favour of least cost abatement, both in principle and in practice (including in relation to the Safeguard Mechanism).

Pre-commercial technology

Enabling the broader transition

BCA recognises the importance of technology to drive emissions reduction and has advocated for governments to play a role in supporting pre-commercial technology.

BCA has advocated for a regulatory framework that is predictable, technology neutral, adaptable and flexible, and for the transition to be proactively managed (both so Australia can take advantage of available opportunities and to address distributional impacts).

Guiding principles

Balanced

Fact-based

BCA's advocacy on climate change appears to be underpinned by a recognition of both the opportunities that are available to Australia from the energy transition and the costs that face Australia from inaction.

BCA's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused BCA generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions. For example, BCA had argued in mid-2020 that Australia should aim to meet its targets without relying on Kyoto carryover credits. The association subsequently hardened its position against the use of such credits.

Technology neutral BCA generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Canadian Chamber of Commerce

We have found there to be some, non-material, misalignment between the climate policy advocacy of the Canadian Chamber of Commerce (CCC) and BHP's August 2020 Global Climate Policy Standards.

While we welcome the CCC's focus on achieving net zero emissions by 2050, we believe there is room for the CCC to strengthen its position on mandatory Scope 3 reporting and low to zero GHG emissions hydrogen production, and ensure it provides appropriate context on the future role of fossil fuels.

On the whole, we believe we sufficiently benefit from our membership of the CCC to continue our membership at this point in time. In particular, we value the opportunities for sharing of best practice and supporting policy development presented through our involvement in the Net Zero Council established by the CCC.

Background

Overview

A national and multi-sector industry association. It has over 200,000 members.

2022 membership fee Governance role

Less than US$100,000 None

Policy outcomes

Global agreements CCC has advocated for greater international cooperation on climate policy and commended the Canadian Government on its participation in COP26.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CCC has described Canada's net zero by 2050 goal as a 'necessity' and established a Net Zero Council to support 'research and advocacy designed to advance Canada's pathway to net-zero'.

CCC has recognised the important role governments play in setting targets and welcomed both the Canadian Net Zero Emissions Accountability Act and the 2030 Emissions Reduction Plan.

CCC has advocated for an 'efficient and cost-effective approach to climate change'. This has included carbon pricing (and associated arrangements, such as border carbon adjustments) and a range of other fiscal and regulatory measures.

CCC has advocated for the Canadian Government to 'accelerate Canada's net zero transformation through supporting innovation, propelling clean tech projects, and growing zero emission technology manufacturing'.

CCC has advocated on the link between labour and decarbonisation, the economic potential presented by the circular economy, the need for a national adaptation strategy, measures to accelerate the electrification of the Canadian economy and the opportunity to expand Canada's critical mineralrelated industries.

In January 2022, CCC advocated that the Canadian Securities Administrators should not integrate Scope 3 emissions 'into disclosure requirements at this time', on the basis that mandatory Scope 3 reporting is currently not practical for issuers. However, BHP is supportive of the concept of mandatory reporting of Scope 3 emissions, subject to any such requirement reflecting the inherent data limitations associated with calculating Scope 3 emissions.

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Appendix A – Summary of association advocacy continued

Guiding principles

Balanced

Fact-based

CCC's advocacy generally appears to be balanced between maintaining the competitiveness of Canadian businesses and highlighting the upside presented by the energy transition.

CCC generally appears to be fact-based in its advocacy. However, at times, the association has used language on the future role of fossil fuels that lacks important context. For instance, in December 2020, CCC noted that 'The demand for Canadian energy, including fossil fuels, remains high for the foreseeable future. The Canada Energy Regulator suggests that while coal and oil will decline in use while natural gas and renewable use rises, crude oil production still has the potential to see a 49% increase from 2018 levels to 2040'. The association, does not, however, provide information on how this forecast could be affected if governments around the world adopted more ambitious climate policies (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

In a recent submission to a consultation process on the Canadian Government's proposed Clean Hydrogen Investment Tax Credit, CCC framed hydrogen derived from natural gas and biomass as one pathway for 'clean hydrogen production', without stipulating any requirement for such production to be coupled with carbon capture and storage. We believe CCC should be clearer on this point and the broader need to ensure future hydrogen production is aligned with national net zero by 2050 goals.

Focused CCC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CCC generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Carbon Market Institute

We have found there to be alignment between the climate policy advocacy of the Carbon Market Institute (CMI) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and multi-sector industry association. It has over 140 members, drawn from all sides of Australia's carbon market.

2022 membership fee Governance role

Less than US$100,000 None

Policy outcomes

Global agreements CMI has advocated for international cooperation on carbon market development, both in principle and in practice.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CMI's policy statement maintains that Australia should adopt policies aligned with the 'Paris Agreement goal to pursue limiting warming to 1.5°C'. CMI has reflected this position in its advocacy.

CMI has advocated (in principle and in practice) for Australia to set a goal of net zero 'by or before 2050' and to adopt more ambitious interim targets.

CMI's policy statement maintains that Australia should 'support economy-wide market mechanisms that provide a clear and long-term investment signal for economy-wide transformational emissions reductions. In line with this position, CMI has been a long and prominent advocate of reforming the Safeguard Mechanism.

CMI has advocated (in principle and in practice) for policy measures to support the development and deployment of technologies needed to enable decarbonisation.

CMI has advocated for the establishment of a 'Just Transition agency or framework', and the adoption of a mandatory and internationally aligned climate-risk disclosure framework.

Guiding principles

Balanced

CMI's advocacy generally appears to be balanced between 'help[ing] business manage risks and capitalise on opportunities in the transition to a net-zero emissions economy'.

Fact-based The CMI's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused CMI generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CMI generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Chamber of Minerals and Energy of Western Australia

We have found there to be alignment between the climate policy advocacy of the Chamber of Minerals and Energy of Western Australia (CME) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A state-based and sector-specific industry association. It has over 180 members.

2022 membership fee Governance role

US$500,000–US$1 million Board member

Policy outcomes

Global agreements CME's position statement provides that 'climate change is a global challenge requiring coordinated action at international, national and sub-national levels' and provides an explicit endorsement of the Paris Agreement.

Paris Agreement goals

CME's position statement supports the aims of the Paris Agreement and the goal of net zero by 2050. In line with this position, CME has contributed to the development of climate policies, supported efforts to expand the production of critical minerals, and promoted the activities being taken by its members to reduce GHG emissions.

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CME has advocated that Australia 'must actively contribute' to the aims of the Paris Agreement and welcomed both the net zero by 2050 goals of the Australian and Western Australian governments.

CME's position statement highlights the importance of national coordination, policy stability, transparent price signals, the promotion of lowest cost abatement, and providing appropriate consideration to the competitiveness of trade exposed industries. In line with these positions, CME has advocated on various climate policies and related issues.

CME has advocated (in principle and in practice) for policies that support the development and deployment of technologies required to reduce emissions.

CME's position statement highlights the importance of a 'sustainable development approach to climate policy' and 'ensur[ing] a just transition for those affected by change'. CME has also supported efforts by the Australian and West Australian Government to expand the production of critical minerals in the State.

Guiding principles

Balanced

CME's advocacy generally appears to be balanced between pushing for 'practical, competitiveness and sustainable' policy settings, and recognising both the need for, and opportunities presented by, decarbonisation.

Fact-based The CME's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused CME generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CME generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Confederation of British Industry

We have found there to be alignment between the climate policy advocacy of the Confederation of British Industry (CBI) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and multi-sector industry association. It has over 190,000 members.

2022 membership fee Governance role

Less than US$100,000 None

Policy outcomes

Global agreements CBI has advocated in support of the UN Framework Convention on Climate Change (UNFCCC) process and the Paris Agreement, and for the United Kingdom to play an active role in 'rais[ing] global ambitions' as host of COP26.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CBI has advocated in favour of 'limiting the average global temperature rise to 1.5°C' and the goal of net zero by 2050. CBI has also advocated for business to accelerate their decarbonisation plans, and launched campaigns on how the British Government and industry can achieve the aims of the Paris Agreement.

CBI has advocated for the British Government to set a net zero by 2050 target and welcomed the British Government's revised 2030 target.

CBI has advocated for policies that are transparent, predictable, based on cost/benefit analysis and are market-based (including carbon pricing).

CBI has emphasised the important role government can play in helping to scale-up and commercialise technology and advocated for policies in line with this position.

CBI has highlighted the need to deliver a 'just and fair transition', and participated in the development of a 'set of core principles of fairness' to guide how 'government and business can best work together to support our transition to a carbon neutral economy'.

Guiding principles

Balanced

Fact-based

CBI has stated that the 'costs of not acting on climate change are significantly larger than transitioning to net zero'. The association's climate policy advocacy is largely centred on how the United Kingdom and British businesses can best take advantage of the opportunities presented by decarbonisation.

The CBI's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused CBI generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CBI generally adopts an 'all of the above' approach in terms of the technologies required to achieve the aims of the Paris Agreement.

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Appendix A – Summary of association advocacy continued

Consejo Minero

We have found there to be alignment between the climate policy advocacy of Consejo Minero and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and sector-specific industry association. It has ~20 members.

2022 membership fee Governance role

US$500,000 – US$1 million Board member

Policy outcomes

Global agreements Consejo Minero recognises that 'climate change is a global challenge that must be understood and addressed by all society agents' and supports 'the implementation of a binding global agreement on climate change'.

Paris Agreement goals

Emissions reduction targets

Consejo Minero supports 'the implementation of a binding global agreement on climate change', including specifically the Paris Agreement. It has also emphasised the mining sector's commitment to helping Chile fulfil its objective of carbon neutrality by 2050.

Consejo Minero has: advocated in favour of including Chile's carbon neutrality by 2050 goal in the country's Climate Change Framework Law; emphasised the mining sector's commitment to helping Chile fulfil its 2030 emissions reduction targets; and actively contributed to the development of Chile's National Mining Policy.

Least cost abatement

Pre-commercial technology

Enabling the broader transition

Consejo Minero's policy principles highlight the importance of cost effectiveness, minimising impacts on vulnerable sections of the community, and market-based instruments. In line with this principles, Consejo Minero has engaged on various climate policies.

Consejo Minero's policy principles highlight the importance of 'renewable resources and other low-emission technologies', and the association participated heavily in the development of the National Mining Policy, which includes (among other things) a goal to accelerate the deployment of zero emission fleets.

Consejo Minero has endorsed the 'implementation of climate change adaptation measures in the communities located around the operations' and frequently highlights the role the Chilean mining sector can play in supplying the minerals needed to enable the global shift to a low-carbon economy.

Guiding principles

Balanced

Fact-based

Consejo Minero generally appears balanced in its climate advocacy. The association notes the challenges the mining sector will face in decarbonising its operations, while also highlighting the considerable opportunities presented to the mining sector by the global shift to a low-carbon economy.

Consejo Minero's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused Consejo Minero generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral Consejo Minero generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

International Copper Association

We have found there to be alignment between the climate policy advocacy of the International Copper Association (ICA) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A global and commodity-specific industry association. It has around 30 members.

2022 membership fee Governance role

US$2.5 million – US$5 million Board member

Policy outcomes

Global agreements ICA has expressed support for the UNFCCC process and highlighted that broad collaboration will be required to achieve the aims of the Paris Agreement. ICA also highlights and supports the contribution of the copper industry to the United Nations Sustainable Development Goals.

Paris Agreement goals

Emissions reduction targets

ICA has emphasised the need to achieve the aims of the Paris Agreement and the role the copper industry can play in enabling the low-carbon transition. In line with these positions, ICA has commissioned research on decarbonising copper mining and collaborated with key stakeholders to help implement China's dual carbon targets.

As a global association, ICA has tended not to comment on the emissions reduction targets of individual countries. The key exception is the European hub of ICA, which has expressed support for 'the EU's climate ambitions for 2030 and 2050'.

Least cost abatement

Pre-commercial technology

Enabling the broader transition

ICA has advocated for a range of measures aimed at supporting least cost abatement, at the global and regional levels.

ICA has highlighted the essential role of copper in underpinning the technologies required to decarbonise the global economy. On a regional level, ICA has supported policies aimed at bolstering innovation in the copper value chain.

ICA has highlighted the need to address energy poverty and electrical safety as part of the EU's broader push to ensure a safe and inclusive transition. ICA also promotes the Copper Mark, which is used to demonstrate the copper industry's contribution to the United Nations Sustainable Development Goals'.

Guiding principles

Balanced

Fact-based

ICA's advocacy generally appears to be balanced between upholding the competitiveness of the copper industry and highlighting the upside presented by the energy transition.

ICA's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused ICA generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral ICA generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

International Council on Mining and Metals

We have found there to be alignment between the climate policy advocacy of the International Council on Mining and Metals (ICMM) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A global and sector-specific industry association. It has around 30 company members.

2022 membership fee Governance role

US$1 million – US$2.5 million Board member

Policy outcomes

Global agreements ICMM's position statement recognises 'the need for an urgent global response to the threat of climate change, across all areas of society and the economy'.

Paris Agreement goals

ICMM's position statement recognises 'the need to support the goals of the Paris Agreement'. The members of ICMM have also collectively committed 'to a goal of net zero Scope 1 and 2 greenhouse gas (GHG) emissions by 2050 or sooner'.

Emissions reduction targets

Least cost abatement

Pre-commercial technology

As a global association, ICMM has tended not to comment on the emissions reduction targets of individual countries.

ICMM's position statement highlights the importance of technology neutral and market-based approaches, and broad-based, predictable and long-term carbon pricing.

ICMM supports efforts to promote innovation and the development and deployment of low emissions technology. ICMM has been acting on this position largely though its Innovation for Cleaner, Safer Vehicles initiative.

Enabling the broader transition

ICMM's position statement highlights the importance climate-related disclosures, the circular economy and working with communities on adaptation.

Through its Skills for our Common Future initiative, ICMM is partnering with others 'to develop the tools and resources to help [communities] secure their futures in an increasingly automated, climate-stressed and unpredictable world'.

ICMM is a signatory of the Paris Peace Forum's call to action on the responsible sourcing and production of critical minerals, and has recently highlighted the actions the mining industry can and should take to uphold human rights during the energy transition.

Guiding principles

Balanced

ICMM frequently highlights the longstanding commitment of the mining and metals industry to sustainable development, and the fundamental role the industry has to play in addressing climate change'.

Fact-based ICMM's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused ICMM generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral ICMM generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Minerals Council of Australia

We have found there to be some, non-material, misalignment between the climate policy advocacy of the Minerals Council of Australia (MCA) and BHP's August 2020 Global Climate Policy Standards.

We appreciate MCA's engagement on major policy issues like the Safeguard Mechanism. However, the association has, at times, undertaken advocacy that does not appear to have been appropriately focused (such as commenting on the draft European Union Sustainable Financing Taxonomy) or given appropriate context to the future role of fossil fuels.

On the whole, we believe we sufficiently benefit from our membership of MCA to continue with membership at this point in time. In particular, we value the association's: work in driving the Climate Action Plan and Towards Sustainable Mining accountability framework; focus on maintaining the competitiveness of the Australian mining sector in an increasingly challenging domestic and international economic context; and role in helping the mining industry and the broader community navigate the COVID-19 pandemic.

Background

Overview

A national and sector-specific industry association. It has around 120 full and associate members.

2022 membership fee Governance role

US$1 million – US$2.5 million Board member

Policy outcomes

Global agreements MCA has recognised the need for global action and Australia's participation in global agreements – both in principle and in practice.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

MCA has confirmed 'the industry's ambition to achieve net zero emissions by 2050 in support of the goals of the Paris Agreement'. In line with this position, the MCA has: developed and maintained its Climate Action Plan; commenced implementation of the Towards Sustainable Mining framework; contributed to the development of various climate policies and supported efforts to expand the production of critical minerals in Australia.

MCA has welcomed the previous Australian Government's net zero by 2050 target and the current Australian Government's Climate Change Act and legislated target of reducing GHG emissions by 43% on 2005 levels by 2030.

MCA's position statement highlights the importance of pursuing least cost abatement, market-based policy measures, policy certainty and investments in low emission technologies. In line with these positions, the MCA has advocated on various climate policies and related issues.

MCA has advocated in favour of policies that support the development and deployment of pre-commercial technologies – both in principle and in practice.

MCA has supported a range of measures to expand the production of critical minerals in Australia.

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Appendix A – Summary of association advocacy continued

Guiding principles

Balanced

Fact-based

Focused

MCA's advocacy generally appears to be balanced between upholding the competitiveness of Australia's mining industry and highlighting the upside presented by the energy transition.

MCA generally appears to be fact-based in its advocacy. However, at times, the association has used language on the future role of fossil fuels that lacks important context. For instance, MCA commissioned research on future demand for thermal coal that took account of current policy settings, but did not give full consideration to how demand could be affected if governments around the world adopted more ambitious climate polices (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

In December 2020, MCA provided feedback to the European Commission, arguing that the draft European Union Sustainable Financing Taxonomy should treat 'clean energy sources such as nuclear power and carbon capture utilisation and storage (CCUS)' equally as other clean energy technologies. In July 2021, MCA issued a media release highlighting free trade-related concerns with the European Union's proposed Carbon Border Adjustment Mechanism. Regardless of the substance of the underlying claims made by MCA, it is not clear to BHP that either of these interventions in another jurisdiction's policy process represented the best use of the MCA's advocacy efforts.

In 2019, MCA advocated in support of carrying over 'emissions reductions from the first and second Kyoto commitment periods' to help achieve Australia's 2030 target. In August 2020, following the release of BHP's Global Climate Policy Standards, the MCA noted the 'use of Kyoto carryover credits was an issue for the government'.

Technology neutral MCA generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Mining Association of Canada

We have found there to be alignment between the climate policy advocacy of the Mining Association of Canada (MAC) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and sector-specific industry association. It has around 110 full and associate members.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements MAC's policy principles recognise that 'climate change is a global issue that requires a global solution'. MAC has also expressed support for climate action that is consistent with the aims of the Paris Agreement.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

MAC has expressed support for climate action that is consistent with the aims of the Paris Agreement. In line with this position, MAC has: developed a new Climate Change Protocol under the Towards Sustainable Mining accountability framework; contributed to the development of key emissions reduction policies; and advocated for Canada 'to play a much more significant role in providing the materials the world needs to get to net-zero'.

MAC does not appear to have directly commented on the emissions reduction targets or goals set by the Canadian Government.

MAC's policy principles outline the association's views on how the Canadian Government can achieve effective and efficient climate change policy. They include an endorsement of carbon pricing and the need to address competitiveness concerns. In line with these principles, MAC has engaged on various climate policies and related issues.

Pre-commercial technology

Enabling the broader transition

MAC has advocated (in principle and in practice) for policy measures to support the technologies required to help the mining sector decarbonise.

MAC has frequently advocated for Canada 'to maximize domestic production of low carbon metals and materials needed to meet projected clean technology demand'. MAC has also engaged with the Canadian Government on its proposed approach to a 'people-centred just transition'.

Guiding principles

Balanced

MAC's advocacy generally appears to be balanced between upholding the competitiveness of the Canadian mining sector and highlighting the opportunities presented to Canada by decarbonisation.

Fact-based MAC's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused MAC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral MAC generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

New South Wales Minerals Council

We have found there to be some, non-material, misalignment between the climate policy advocacy of the New South Wales Minerals Council (NSWMC) and BHP's August 2020 Global Climate Policy Standards.

The NSWMC has tended to emphasise the risks associated with the transition of the electricity sector, without engaging during our 2023 industry association review period (at least publicly) with various policy processes designed to mitigate these risks. Furthermore, the NSWMC has not always given appropriate context on the future role or GHG emissions profile of fossil fuels.

On the whole, we believe we sufficiently benefit from our membership of the NSWMC to continue with membership at this point in time. In particular, we value the assistance the NSWMC has provided, and continues to provide, as we proceed with our intended managed process to cease mining at New South Wales Energy Coal by the end of FY2030 and prepare for closure.

Background

Overview

A state-based and sector-specific industry association. It has around 80 full and associate members.

2022 membership fee Governance role

US$500,000 – US$1million Member of the Executive Committee

Policy outcomes

Global agreements NSWMC acknowledges that 'sustained global action is required to reduce the risks of human-induced climate change' and supports 'Australia's participation in global agreements, including the [UNFCCC]'.

Paris Agreement goals

NSWMC's position statement supports 'Australia's participation in global agreements, including the [UNFCCC]', and the 'NSW Government and Australian Government target of reaching net-zero emissions by 2050'. In line with these principles, NSWMC has contributed to the development of emissions reduction policies; and supported efforts by the NSW Government to position the State as a major supplier and processor of critical minerals.

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

NSWMC's position statement supports the 'NSW Government and Australian Government target of reaching net-zero emissions by 2050'.

NSWMC's position statement maintains that policy frameworks should 'provide for least-cost abatement … and recognise that all sectors of the economy have a role to play in meeting emission reduction goals, including the resources sector'. In line with these principles, NSWMC has engaged on various climate policies and related issues.

NSWMC has advocated in favour of policies that 'the research, development and deployment of new and emerging low emissions technologies' – in principle and in practice.

NSWMC has advocated in favour of reforming the NSW planning regime, with the goal of allowing mining operations 'to amend their existing post-mining approval conditions in response to community needs so local mining communities receive the best possible outcomes once mines reach the end of their operating lives'. Such a change would enable a more community-centric approach to an equitable transition.

NSWMC has also supported efforts by the NSW Government to position the State as a major supplier and processor of critical minerals.

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Appendix A – Summary of association advocacy continued

Guiding principles

Balanced

Fact-based

NSWMC has highlighted the opportunities presented by the energy transition to NSW (in terms of increased demand for critical minerals) and the steps being taken by mining companies to decarbonise.

The association's advocacy on the electricity system, however, tends to have more of a focus on the costs and risks associated with the energy transition, without giving due consideration (at least in public) to the policy solutions needed to ensure a decarbonised grid can supply electricity as cheaply and reliably as possible.

NSWMC has, at times, used language on the future role of fossil fuels that lacks important context. For instance, NSWMC has noted that coal exports are 'likely to contribute strongly to our economy for decades', based on forecasts of coal demand published by the NSW Government and the IEA that appear to be based on current policies. The association does not, however, provide information on how these forecasts could be affected if governments around the world adopted more ambitious climate polices (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

NSWMC's Responsible Mining campaign makes a reference to NSW's 'high quality, low-emissions coal'. This framing could be interpreted as the NSWMC suggesting coal produced from NSW is a source of low GHG emissions energy. If the intent of NSWMC was to highlight that coal produced from NSW results in lower GHG emissions compared to coal produced from other jurisdictions, the association should be clearer in its language.

Focused NSWC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral NSWMC generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Queensland Resources Council

We have found there to be some, non-material, misalignment between the climate policy advocacy of the Queensland Resources Council (QRC) and BHP's August 2020 Global Climate Policy Standards.

In November 2021, the QRC advocated in a manner that presented a misleading view of the electricity system in Queensland.

The Findings and Outcomes section of this Report provides further information with respect to our determination to remove suspension of our membership of the QRC effective 1 June 2023.

Background

Overview

A state-based and sector-specific industry association. It has around 180 full and services members.

2022 membership fee Governance role

US$500,000 – US$1million1,2 Board member

Policy outcomes

Global agreements The QRC recognises that 'climate change is a critical global challenge' and that climate policies 'must be consistent with Australia's participation in global agreements, including the Paris Agreement'.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

The QRC's position statement supports the aims of the Paris Agreement, 'action to achieve the commitments under the [Paris Agreement]' and 'the [MCA's] industry ambition to achieve net zero emissions by 2050'. In line with these positions, the QRC has contributed to the development of the Queensland Resource Industry Development Plan; and supported efforts by the Australian and Queensland governments to expand the production of critical minerals in the State.

The QRC's position statement supports 'the [MCA's] industry ambition to achieve net zero emissions by 2050'. While the QRC does not appear to have commented on the emissions reduction targets of either the Federal or State governments during our review period, it has acknowledged the need for action to meet 'emissions targets'.

The QRC's position statement supports market-based approaches that prioritise least cost abatement, maintain international competitiveness, are technology neutral, and 'deliver a clear, predictable and long-term price signal'. In line with these principles, the QRC has engaged on various climate policies and related issues.

Pre-commercial technology

Enabling the broader transition

Guiding principles

Balanced

The QRC has advocated for policy measures that support the development and deployment of low emission technologies – in principle and in practice.

The QRC has highlighted the importance of local adaptation planning and supported efforts by the Australian and Queensland Governments to expand the production of critical minerals in the State.

The QRC's advocacy generally appears to be balanced between upholding the competitiveness of the Queensland mining sector and highlighting the opportunities presented to Queensland by decarbonisation. An illustrative example is the QRC response to the Queensland Government's Energy and Jobs Plan. The QRC noted that while the plan to achieve 70% renewable energy by 2032 did 'come with some risk' and would need to be 'managed very tightly', it did provide an 'enormous opportunity' for the resources industry, given the sector supplies many of the raw materials needed to build renewable energy infrastructure.

Fact-based In November 2021, the QRC issued a media release that noted: 'Right now, steel can only be produced commercially by using metallurgical coal, and thermal coal is the only 100 percent reliable way to produce energy in Queensland'. The QRC later updated this release to note that 'thermal coal and gas are the only 100 percent reliable way to produce energy in Queensland'. Even with this update, the statement presents a misleading view of electricity generation in Queensland, as it overlooks the decades-long role played by hydroelectricity in the State (including the 570 MW Wivenhoe pumped storage plant).

Focused The QRC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral The QRC generally appears to advocate in favour of technology neutral policy frameworks.

1 Fees for the QRC relate to the BHP Mitsubishi Alliance (BMA). BMA is a 50:50 joint venture between BHP and Mitsubishi Development that was formed in 2001. 2 BHP suspended its member of the QRC in October 2021, however we continued to meet our obligations under the QRC constitution, which included the payment of membership fees.

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Appendix A – Summary of association advocacy continued

South Australian Chamber of Mines and Energy

We have found there to be alignment between the climate policy advocacy of the South Australian Chamber of Mines and Energy (SACOME) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A state-based and sector-specific industry association. It has around 200 members.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements SACOME position statement 'supports the Paris Agreement as a critical element of the global response to climate change'.

Paris Agreement goals

SACOME's position statement supports the aims of the Paris Agreement and the 'target of net zero emissions by 2050'. In line with these positions, SACOME has contributed to the development of climate policies and supported efforts by the South Australian Government to expand the production of critical minerals in the State.

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

SACOME does not appear to have directly commented on the emissions reduction targets of either the South Australian or Australian Governments during our review period. The association has, however, indicated it shares the support of its member companies 'for a target of net zero emissions by 2050'.

SACOME's position statement outlines a number of policy principles. These are centred on achieving least cost abatement and preserving the trade competitiveness of Australian industries, and include an endorsement of market-based mechanisms, carbon pricing, trade and technology neutrality, and effective coordination between climate and energy policy and Federal and State governments. In line with these principles, SACOME has engaged on various climate policies and related issues.

SACOME has advocated (in principle and in practice) for policy measures that support the development and deployment of low emission technologies.

SACOME's position statement highlights the importance of measures to build resilience and support local adaptation. SACOME has also supported efforts by the South Australian Government to expand the production of critical minerals in the State.

Guiding principles

Balanced

Fact-based

SACOME has adopted a notably constructive approach to climate policy advocacy, with the association advocating for policy proposals to address challenges and opportunities associated with the transition to a low carbon economy of relevance to the mining industry.

SACOME's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused SACOME generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral SACOME generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

United States Chamber of Commerce

We have found there to be some, non-material, misalignment between the climate policy advocacy of the United States Chamber of Commerce (US Chamber) and BHP's August 2020 Global Climate Policy Standards.

We welcome the US Chamber's commitment to climate action and embrace of carbon pricing. However, we believe there is room for the US Chamber to strengthen its position on fuel efficiency standards and mandatory Scope 3 reporting, and ensure it provides appropriate context on the future role of fossil fuels.

On the whole, we believe we sufficiently benefit from our membership of the US Chamber to continue with membership at this point in time. In particular, we value the deep expertise and advocacy of the US Chamber on matters relating to fiscal policies, trade and geopolitics.

Background

Overview

A national and multi-sector industry association. It has around 3 million members.

2022 membership fee Governance role

US$100,000 – US$500,000 None

Policy outcomes

Global agreements US Chamber has recognised the importance of international action and cooperation. In line with this position, US Chamber welcomed 'President Biden's action to re-join the Paris Climate Agreement'.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

US Chamber has expressed support for 'US participation in the Paris Agreement' and welcomed the Biden Administration's decision to re-join the Paris Agreement. In line with this position, US Chamber has: engaged on climate policy debates; supported efforts to improve access to critical minerals supply; and provided guidance to businesses on how they can accelerate their decarbonisation progress.

US Chamber has advocated for 'reducing emissions as low as we can and fast as we can, while ensuring that any national targets and timetables are realistic, achievable, appropriately account for U.S. economic interests and work to address impacts to trade-exposed, hard-to-adapt and energy intensive sectors'. In line with this position, US Chamber noted the Biden administration's new 2030 target, and expressed its support for the Global Methane Pledge.

US Chamber's position statement highlights the importance of 'acknowledg[ing] the costs of action and inaction and the competitiveness of the US economy', and market-based approaches to emissions reduction. US Chamber has separately indicated that it supports an 'economy-wide carbon price'. In line with these positions, US Chamber has engaged on various climate policies.

Pre-commercial technology

Enabling the broader transition

In March 2020, US Chamber stated that it welcomed the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule issued by the Trump Administration, on the basis that it appeared to provide 'a workable path forward on a unified national program that provides regulatory certainty while strengthening fuel economy standards and continuing emissions reductions'. It is not clear, however, that the SAFE Vehicles Rule would have resulted in more cost-effective abatement in the transport sector relative to the more stringent fuel efficiency standards that it replaced – particularly given the reported concerns about the quality of the cost-benefit analysis that underpinned the regulatory change process.

US Chamber has advocated (in principle and in practice) for policy measures that help accelerate the development and deployment of new technologies.

US Chamber has advocated (in principle and in practice) for policy measures that support climate resilient infrastructure. US Chamber has also been a strong proponent of expanding the domestic production and processing of the minerals required to enable the energy transition, with a particular focus on permitting reform.

In June 2022, US Chamber advocated that the Securities and Exchange Commission (SEC) should make Scope 3 reporting voluntary, rather than mandatory, given the difficulties associated with calculating Scope 3 emissions. However, BHP supports the concept of mandatory reporting of Scope 3 emissions, subject to any such requirement reflecting the inherent data limitations associated with calculating Scope 3 emissions.

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Guiding principles

Balanced

US Chamber's advocacy generally appears to be balanced between upholding the competitiveness of the US business community highlighting the opportunities presented by decarbonisation. Notably, US Chamber's position statement is underpinned by the recognition that 'inaction is not an option'.

Fact-based US Chamber generally appears to be fact-based in its advocacy. However, at times, the association used language on the future role of fossil fuels that lacks important context. For instance, in March 2022, the US Chamber noted that 'Oil and natural gas are the primary sources of [reliable] energy, and the Department of Energy forecasts they will remain the most-consumed sources of energy in the U.S. through at least 2050'. The association does not, however, provide information on how this forecast could be affected if governments around the world adopted more ambitious climate polices (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

Focused US Chamber generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral US Chamber generally appears to advocate in favour of technology neutral policy frameworks.

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bhp.com

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Industry Association Review

June 2023

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Contents

Executive Summary 3 Our approach 4 Findings and outcomes 5 Appendix A 6

Disclaimer and limitations

Objectivity

The views and conclusions expressed in this Report are those of BHP. No association was consulted on BHP's approach or provided with BHP's assessment or proposed outcomes prior to inalisation of this Report. BHP has sought (with KPMG's input) to provide a balanced and fair summary of the policy and advocacy positions of each association included in the scope of our review, but we recognise that the nature of a review of policy and advocacy positions in any area of public debate necessarily involves interpretation, judgement and opinion.

We have also not undertaken any veriication of the public information regarding any of the associations referred to in this Report and BHP makes no representation regarding the accuracy of any such information, including the information regarding their advocacy positions as contained in Appendix A.

Evidence-based review

The review is based on publicly available information. The review could not, and therefore did not, encompass or take into account information which may have been discussed 'behind closed doors', or subsequently amended after the review period. BHP did not separately verify the publicly available information on which the review was based.

Executive Summary

The purpose of this Report is to provide the outcomes of our review of policy alignment between BHP and our material association memberships in relation to climate change.

We join, and remain members of, industry associations that we believe can help achieve better outcomes on public policy, practice and/or standards.

We also believe that we can have a positive impact on standards and advocacy working with and within industry associations.

Our 2023 industry association review focused on 15 association memberships we consider to be material. Of these, we found: • 10 were aligned with our August 2020 Global Climate Policy Standards.

• Five had some, non-material misalignment: the Canadian Chamber of Commerce (CCC), Minerals Council of Australia (MCA), New South Wales Minerals Council (NSWMC), Queensland Resources Council (QRC) and United States Chamber of Commerce (US Chamber). In relation to: – CCC, MCA and US Chamber, our view is that we derive suicient beneit from our membership of these associations. Accordingly, and consistent with our principles for participating in industry associations, we have determined to remain a member of the CCC, MCA and US Chamber, while actively encouraging these associations to address the identiied areas of misalignment.

– NSWMC, we will remain a member conditional on the association conirming its policy agenda to support the achievement of a reliable, aordable and zero emissions electricity grid.

– QRC, we have decided to resume full membership given that the reason for our suspension in October 2020 has been resolved and given the beneits derived from membership. We will also encourage the association to address the area of misalignment identiied by this review.

• None had material misalignment with our August 2020 Global Climate Policy Standards.

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Future action

In February 2023, we engaged with investors and other stakeholders on possible further improvements we could make to our industry association review approach. Based on the feedback we received, we will be increasing the frequency of our industry association reviews to every two years. In the intervening years, we will publish (as relevant) an update on the progress we have made in addressing identiied areas of misalignment and any relevant indings from our real time monitoring.

Governance

This Report has been approved by the BHP Board.

Our approach

Scope of the review

Our 2023 industry association review considered the climate policy advocacy of in-scope associations in the period January 2020 to February 2023. Fifteen industry associations (see Appendix A) were in scope for the review on the basis that they met at least one of the following two 'materiality' criteria as at July 2022: • our base membership fee in 2022 was equal to or greater than US$100,000; and/or • there is signiicant stakeholder interest in the advocacy of the association (as determined by whether the association was listed on InluenceMap's ranking of industry associations).

Methodology

Assessing alignment and acting on material misalignment

We used the following three-step approach to assess the climate policy advocacy of our material associations: • We commissioned an external party (KPMG) to collect publicly available information on the associations' advocacy (e.g., from association websites, government consultation processes, news reports and social media).

• We assessed the extent to which the advocacy aligned with our August 2020 Global Climate Policy Standards. This assessment considered both the formal position statements of industry associations and their day-to-day advocacy, and focused primarily on advocacy of direct relevance to the mining sector. In determining whether an identiied misalignment was material or not, we considered: – the nature of the identiied misalignment (e.g., does it relate to a fundamental dierence over principle or outcomes? Or is it more of a practical disagreement over the best way to achieve a shared goal?); – the nature of the relevant policy issue (e.g., how crucial is the issue in terms of enabling the achievement of the aims of the Paris Agreement?); and – the consistency and trajectory of association advocacy (e.g., does the identiied misalignment it within a broader pattern of association advocacy, or does it appear to be more of a one-o? Has the advocacy of the association in relation to the identiied misalignment improved over time?).

• For those industry associations that were found to have some, non-material, misalignment, we made a determination of what actions we would take to address the identiied misalignment (having regard to BHP's principles for participating in industry associations).

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Position on the Paris Agreement

One of our guiding principles for participating in industry associations is that the policy advocacy of an industry association should relect the views of its membership. On issues where no broad industry consensus exists, we believe associations should refrain from advocacy.

As a consequence, we generally do not view the absence of an association position on an element of our August 2020 Global Climate Policy Standards as representing, by itself, suficient evidence that a misalignment exists (given such 'silence' could relect a lack of consensus amongst the association's membership).

The only exception relates to the Paris Agreement. Given the centrality of the Paris Agreement to the global effort to address climate change, we consider the absence of a position on the Paris Agreement to represent a material misalignment.

Findings and outcomes

Alignment

Applying the methodology outlined above, we found that, of the 15 material industry associations, there was: • alignment with 10 industry associations; • some, non-material misalignment with ive industry associations, being CCC, MCA, NSWMC, QRC and the US Chamber; and • no material misalignment.

Appendix A provides further detail on our indings.

Actions on non-material misalignment

In determining what actions to take regarding our membership of the ive associations where there was non-material misalignment, we have been guided by the nature of the misalignment and the beneits of membership.

Given these factors, we have decided to remain members of the CCC and MCA. We will actively encourage these associations to address the areas of misalignment identiied.

In relation to the US Chamber, our 2019 industry association review found two material differences (relating to greenhouse gas (GHG) emissions reduction targets and carbon pricing). The US Chamber has largely addressed these differences by committing to work with the Biden Administration in pursuit of its new 2030 emissions reduction target, and by publicly shifting its posture in favour of carbon pricing. Given this, and our view of the beneits of membership, we will remain a member and actively encourage the US Chamber to address areas of misalignment.

In relation to the NSWMC, our 2019 industry association review found one material difference (relating to balancing the energy trilemma). Given there is some similarity between this material difference and one of the areas of misalignment found as part of our 2023 review, and our view that we derive beneit from our membership of NSWMC, we have determined that we will remain a member of NSWMC, although our ongoing membership is subject to the association conirming its policy agenda to support the achievement of a reliable, affordable and zero emissions electricity grid.

Queensland Resources Council

We suspended our membership of the QRC in October 2020. This followed a decision by the QRC to undertake advertising that speciically targeted the overall standing of one political party during the 2020 Queensland election campaign.

As part of our 2023 industry association review, we considered: • The QRC's adherence to the Political Engagement Policy adopted by the QRC Board in February 2021. Based on our review of the QRC's public commentary (including media releases, interviews and social media activity) from February 2021 to February 2023, it is our view that the QRC has adhered to its Political Engagement Policy.

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• Advocacy alignment. As we note above, our 2023 industry association review found that there is some, non-material, misalignment between the climate policy advocacy of the QRC and BHP's August 2020 Global Climate Policy Standards. The identiied area of misalignment related to one media release issued by the QRC and does not appear to form part of a broader pattern of advocacy.

• The beneits of QRC membership. The key drivers of the value QRC oers include: – Providing a consolidated industry voice to the Queensland Government on matters of signiicance to the mining sector. In the past, this has included coordinating how the sector and government could protect workers and the community during the COVID19 pandemic. More recently, the QRC has played a key role in advocating against the Queensland Government's increase in royalty rates that threaten the State's attractiveness as an investment destination, and engaging with the Queensland Government on the sector's ongoing commitment to address sexual assault and sexual harassment in its workforce.

– Promoting the positive contribution that the mining sector makes to Queensland, in terms of direct and indirect employment, procurement spend and payments to government. The QRC produces an annual economic report, which underpins its promotional eorts in this regard.

– Supporting improved inclusion and diversity practices in the Queensland mining sector. Most notably, the QRC highlights and celebrates best practice through its QRC Indigenous Awards and Women in Mining and Resources Queensland.

– Addressing the skills crisis facing the mining sector. The QRC manages a partnership with the Queensland Government (the Queensland Minerals and Energy Academy) that seeks to put 'students onto pathways into the resources sector and other science, technology, engineering and maths (STEM) industries'.

– Driving sector performance through its various technical working groups. In the past, we found these working groups provided a cost-eective means of staying up-to-date on potential legislative/regulatory changes, as well as industry best practice.

Based on the above, we have determined to remove suspension of our membership effective 1 July 2023.

Appendix A – Summary of association advocacy

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Appendix A – Summary of association advocacy continued

Australian Industry Greenhouse Network

We have found there to be alignment between the climate policy advocacy of the Australian industry Greenhouse Network (AIGN) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A network of ~20 Australian-based industry associations and corporations that see value in joint action on climate change to promote sustainable industry development.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements AIGN's formal principles emphasise the signiicance of global action and the need for global agreement. AIGN has relected these principles in its advocacy.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

AIGN has repeatedly expressed support for the aims of the Paris Agreement and has referred to these aims in setting the parameters of its advocacy.

AIGN has expressed support for the Australian Government's emissions reduction targets and proposal to update these targets every ive years.

AIGN's formal principles are focused on the delivery of 'least cost, environmentally effective and equitable outcomes for Australia'. In line with these principles, AIGN has: engaged on the proposed reform of the Safeguard Mechanism; supported measures that accelerate the development of pre-commercial technology and nationally consistent policy approaches; and advocated in favour of allowing 'access to genuine international units'.

Pre-commercial technology

Enabling the broader transition

AIGN's formal principles emphasise the important role government can play in unlocking 'irst-of-a-kind' technologies. AIGN has relected these principles in its advocacy.

AIGN has advocated in favour of integrated and transparent policy frameworks, the importance of taking into account different abatement capabilities between and within countries, and the pursuit of equitable outcomes.

Guiding principles

Balanced

AIGN's advocacy appears to be balanced between upholding business competitiveness and highlighting the upside presented by the energy transition.

Fact-based AIGN's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused AIGN generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions. For example, AIGN previously expressed support for the use of Kyoto carryover credits, but does not appear to have done so during the review period.

Technology neutral AIGN generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Business Council of Australia

We have found there to be alignment between the climate policy advocacy of the Business Council of Australia (BCA) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and multi-sector industry association. It has approximately 130 members.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements BCA has advocated in favour of international climate cooperation, the Paris Agreement and Australia making a fair contribution to global efforts.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

BCA has expressed support for the aims of the Paris Agreement and has proposed a policy agenda focused on achieving these aims.

BCA has advocated in favour of net zero by 2050, increasing the ambition of Australia's 2030 target, and the Australian Government's new Climate Change Act.

BCA has advocated in favour of least cost abatement, both in principle and in practice (including in relation to the Safeguard Mechanism).

BCA recognises the importance of technology to drive emissions reduction and has advocated for governments to play a role in supporting pre-commercial technology.

BCA has advocated for a regulatory framework that is predictable, technology neutral, adaptable and lexible, and for the transition to be proactively managed (both so Australia can take advantage of available opportunities and to address distributional impacts).

Guiding principles

Balanced

BCA's advocacy on climate change appears to be underpinned by a recognition of both the opportunities that are available to Australia from the energy transition and the costs that face Australia from inaction.

Fact-based BCA's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused BCA generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions. For example, BCA had argued in mid-2020 that Australia should aim to meet its targets without relying on Kyoto carryover credits. The association subsequently hardened its position against the use of such credits.

Technology neutral BCA generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Canadian Chamber of Commerce

We have found there to be some, non-material, misalignment between the climate policy advocacy of the Canadian Chamber of Commerce (CCC) and BHP's August 2020 Global Climate Policy Standards.

While we welcome the CCC's focus on achieving net zero emissions by 2050, we believe there is room for the CCC to strengthen its position on mandatory Scope 3 reporting and low to zero GHG emissions hydrogen production, and ensure it provides appropriate context on the future role of fossil fuels.

On the whole, we believe we suficiently beneit from our membership of the CCC to continue our membership at this point in time. In particular, we value the opportunities for sharing of best practice and supporting policy development presented through our involvement in the Net Zero Council established by the CCC.

Background

Overview

A national and multi-sector industry association. It has over 200,000 members.

2022 membership fee Governance role

Less than US$100,000 None

Policy outcomes

Global agreements CCC has advocated for greater international cooperation on climate policy and commended the Canadian Government on its participation in COP26.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CCC has described Canada's net zero by 2050 goal as a 'necessity' and established a Net Zero Council to support 'research and advocacy designed to advance Canada's pathway to net-zero'.

CCC has recognised the important role governments play in setting targets and welcomed both the Canadian Net Zero Emissions Accountability Act and the 2030 Emissions Reduction Plan.

CCC has advocated for an 'eficient and cost-effective approach to climate change'. This has included carbon pricing (and associated arrangements, such as border carbon adjustments) and a range of other iscal and regulatory measures.

CCC has advocated for the Canadian Government to 'accelerate Canada's net zero transformation through supporting innovation, propelling clean tech projects, and growing zero emission technology manufacturing'.

CCC has advocated on the link between labour and decarbonisation, the economic potential presented by the circular economy, the need for a national adaptation strategy, measures to accelerate the electriication of the Canadian economy and the opportunity to expand Canada's critical mineralrelated industries.

In January 2022, CCC advocated that the Canadian Securities Administrators should not integrate Scope 3 emissions 'into disclosure requirements at this time', on the basis that mandatory Scope 3 reporting is currently not practical for issuers. However, BHP is supportive of the concept of mandatory reporting of Scope 3 emissions, subject to any such requirement relecting the inherent data limitations associated with calculating Scope 3 emissions.

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Appendix A – Summary of association advocacy continued

Guiding principles

Balanced

Fact-based

CCC's advocacy generally appears to be balanced between maintaining the competitiveness of Canadian businesses and highlighting the upside presented by the energy transition.

CCC generally appears to be fact-based in its advocacy. However, at times, the association has used language on the future role of fossil fuels that lacks important context. For instance, in December 2020, CCC noted that 'The demand for Canadian energy, including fossil fuels, remains high for the foreseeable future. The Canada Energy Regulator suggests that while coal and oil will decline in use while natural gas and renewable use rises, crude oil production still has the potential to see a 49% increase from 2018 levels to 2040'. The association, does not, however, provide information on how this forecast could be affected if governments around the world adopted more ambitious climate policies (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

In a recent submission to a consultation process on the Canadian Government's proposed Clean Hydrogen Investment Tax Credit, CCC framed hydrogen derived from natural gas and biomass as one pathway for 'clean hydrogen production', without stipulating any requirement for such production to be coupled with carbon capture and storage. We believe CCC should be clearer on this point and the broader need to ensure future hydrogen production is aligned with national net zero by 2050 goals.

Focused CCC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CCC generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Carbon Market Institute

We have found there to be alignment between the climate policy advocacy of the Carbon Market Institute (CMI) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and multi-sector industry association. It has over 140 members, drawn from all sides of Australia's carbon market.

2022 membership fee Governance role

Less than US$100,000 None

Policy outcomes

Global agreements CMI has advocated for international cooperation on carbon market development, both in principle and in practice.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CMI's policy statement maintains that Australia should adopt policies aligned with the 'Paris Agreement goal to pursue limiting warming to 1.5°C'. CMI has relected this position in its advocacy.

CMI has advocated (in principle and in practice) for Australia to set a goal of net zero 'by or before 2050' and to adopt more ambitious interim targets.

CMI's policy statement maintains that Australia should 'support economy-wide market mechanisms that provide a clear and long-term investment signal for economy-wide transformational emissions reductions. In line with this position, CMI has been a long and prominent advocate of reforming the Safeguard Mechanism.

CMI has advocated (in principle and in practice) for policy measures to support the development and deployment of technologies needed to enable decarbonisation.

CMI has advocated for the establishment of a 'Just Transition agency or framework', and the adoption of a mandatory and internationally aligned climate-risk disclosure framework.

Guiding principles

Balanced

CMI's advocacy generally appears to be balanced between 'help[ing] business manage risks and capitalise on opportunities in the transition to a net-zero emissions economy'.

Fact-based The CMI's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused CMI generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CMI generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Chamber of Minerals and Energy of Western Australia

We have found there to be alignment between the climate policy advocacy of the Chamber of Minerals and Energy of Western Australia (CME) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A state-based and sector-speciic industry association. It has over 180 members.

2022 membership fee Governance role

US$500,000US$1 million Board member

Policy outcomes

Global agreements CME's position statement provides that 'climate change is a global challenge requiring coordinated action at international, national and sub-national levels' and provides an explicit endorsement of the Paris Agreement.

Paris Agreement goals

CME's position statement supports the aims of the Paris Agreement and the goal of net zero by 2050. In line with this position, CME has contributed to the development of climate policies, supported efforts to expand the production of critical minerals, and promoted the activities being taken by its members to reduce GHG emissions.

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CME has advocated that Australia 'must actively contribute' to the aims of the Paris Agreement and welcomed both the net zero by 2050 goals of the Australian and Western Australian governments.

CME's position statement highlights the importance of national coordination, policy stability, transparent price signals, the promotion of lowest cost abatement, and providing appropriate consideration to the competitiveness of trade exposed industries. In line with these positions, CME has advocated on various climate policies and related issues.

CME has advocated (in principle and in practice) for policies that support the development and deployment of technologies required to reduce emissions.

CME's position statement highlights the importance of a 'sustainable development approach to climate policy' and 'ensur[ing] a just transition for those affected by change'. CME has also supported efforts by the Australian and West Australian Government to expand the production of critical minerals in the State.

Guiding principles

Balanced

CME's advocacy generally appears to be balanced between pushing for 'practical, competitiveness and sustainable' policy settings, and recognising both the need for, and opportunities presented by, decarbonisation.

Fact-based The CME's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused CME generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CME generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Confederation of British Industry

We have found there to be alignment between the climate policy advocacy of the Confederation of British Industry (CBI) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and multi-sector industry association. It has over 190,000 members.

2022 membership fee Governance role

Less than US$100,000 None

Policy outcomes

Global agreements CBI has advocated in support of the UN Framework Convention on Climate Change (UNFCCC) process and the Paris Agreement, and for the United Kingdom to play an active role in 'rais[ing] global ambitions' as host of COP26.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

CBI has advocated in favour of 'limiting the average global temperature rise to 1.5°C' and the goal of net zero by 2050. CBI has also advocated for business to accelerate their decarbonisation plans, and launched campaigns on how the British Government and industry can achieve the aims of the Paris Agreement.

CBI has advocated for the British Government to set a net zero by 2050 target and welcomed the British Government's revised 2030 target.

CBI has advocated for policies that are transparent, predictable, based on cost/beneit analysis and are market-based (including carbon pricing).

CBI has emphasised the important role government can play in helping to scale-up and commercialise technology and advocated for policies in line with this position.

CBI has highlighted the need to deliver a 'just and fair transition', and participated in the development of a 'set of core principles of fairness' to guide how 'government and business can best work together to support our transition to a carbon neutral economy'.

Guiding principles

Balanced

CBI has stated that the 'costs of not acting on climate change are signiicantly larger than transitioning to net zero'. The association's climate policy advocacy is largely centred on how the United Kingdom and British businesses can best take advantage of the opportunities presented by decarbonisation.

Fact-based The CBI's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused CBI generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral CBI generally adopts an 'all of the above' approach in terms of the technologies required to achieve the aims of the Paris Agreement.

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Appendix A – Summary of association advocacy continued

Consejo Minero

We have found there to be alignment between the climate policy advocacy of Consejo Minero and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and sector-speciic industry association. It has ~20 members.

2022 membership fee Governance role

US$500,000 – US$1 million Board member

Policy outcomes

Global agreements Consejo Minero recognises that 'climate change is a global challenge that must be understood and addressed by all society agents' and supports 'the implementation of a binding global agreement on climate change'.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

Consejo Minero supports 'the implementation of a binding global agreement on climate change', including speciically the Paris Agreement. It has also emphasised the mining sector's commitment to helping Chile fulil its objective of carbon neutrality by 2050.

Consejo Minero has: advocated in favour of including Chile's carbon neutrality by 2050 goal in the country's Climate Change Framework Law; emphasised the mining sector's commitment to helping Chile fulil its 2030 emissions reduction targets; and actively contributed to the development of Chile's National Mining Policy.

Consejo Minero's policy principles highlight the importance of cost effectiveness, minimising impacts on vulnerable sections of the community, and market-based instruments. In line with this principles, Consejo Minero has engaged on various climate policies.

Consejo Minero's policy principles highlight the importance of 'renewable resources and other low-emission technologies', and the association participated heavily in the development of the National Mining Policy, which includes (among other things) a goal to accelerate the deployment of zero emission leets.

Consejo Minero has endorsed the 'implementation of climate change adaptation measures in the communities located around the operations' and frequently highlights the role the Chilean mining sector can play in supplying the minerals needed to enable the global shift to a low-carbon economy.

Guiding principles

Balanced

Fact-based

Focused

Consejo Minero generally appears balanced in its climate advocacy. The association notes the challenges the mining sector will face in decarbonising its operations, while also highlighting the considerable opportunities presented to the mining sector by the global shift to a low-carbon economy.

Consejo Minero's advocacy generally appears to be fact-based and free of ambiguous terminology.

Consejo Minero generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral Consejo Minero generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

International Copper Association

We have found there to be alignment between the climate policy advocacy of the International Copper Association (ICA) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A global and commodity-speciic industry association. It has around 30 members.

2022 membership fee Governance role

US$2.5 million – US$5 million Board member

Policy outcomes

Global agreements ICA has expressed support for the UNFCCC process and highlighted that broad collaboration will be required to achieve the aims of the Paris Agreement. ICA also highlights and supports the contribution of the copper industry to the United Nations Sustainable Development Goals.

Paris Agreement goals

Emissions reduction targets

ICA has emphasised the need to achieve the aims of the Paris Agreement and the role the copper industry can play in enabling the low-carbon transition. In line with these positions, ICA has commissioned research on decarbonising copper mining and collaborated with key stakeholders to help implement China's dual carbon targets.

As a global association, ICA has tended not to comment on the emissions reduction targets of individual countries. The key exception is the European hub of ICA, which has expressed support for 'the EU's climate ambitions for 2030 and 2050'.

Least cost abatement

Pre-commercial technology

Enabling the broader transition

ICA has advocated for a range of measures aimed at supporting least cost abatement, at the global and regional levels.

ICA has highlighted the essential role of copper in underpinning the technologies required to decarbonise the global economy. On a regional level, ICA has supported policies aimed at bolstering innovation in the copper value chain.

ICA has highlighted the need to address energy poverty and electrical safety as part of the EU's broader push to ensure a safe and inclusive transition. ICA also promotes the Copper Mark, which is used to demonstrate the copper industry's contribution to the United Nations Sustainable Development Goals'.

Guiding principles

Balanced

ICA's advocacy generally appears to be balanced between upholding the competitiveness of the copper industry and highlighting the upside presented by the energy transition.

Fact-based ICA's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused ICA generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral ICA generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

International Council on Mining and Metals

We have found there to be alignment between the climate policy advocacy of the International Council on Mining and Metals (ICMM) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A global and sector-speciic industry association. It has around 30 company members.

2022 membership fee Governance role

US$1 million – US$2.5 million Board member

Policy outcomes

Global agreements ICMM's position statement recognises 'the need for an urgent global response to the threat of climate change, across all areas of society and the economy'.

Paris Agreement goals

ICMM's position statement recognises 'the need to support the goals of the Paris Agreement'. The members of ICMM have also collectively committed 'to a goal of net zero Scope 1 and 2 greenhouse gas (GHG) emissions by 2050 or sooner'.

Emissions reduction targets

Least cost abatement

Pre-commercial technology

As a global association, ICMM has tended not to comment on the emissions reduction targets of individual countries.

ICMM's position statement highlights the importance of technology neutral and market-based approaches, and broad-based, predictable and long-term carbon pricing.

ICMM supports efforts to promote innovation and the development and deployment of low emissions technology. ICMM has been acting on this position largely though its Innovation for Cleaner, Safer Vehicles initiative.

Enabling the broader transition

ICMM's position statement highlights the importance climate-related disclosures, the circular economy and working with communities on adaptation.

Through its Skills for our Common Future initiative, ICMM is partnering with others 'to develop the tools and resources to help [communities] secure their futures in an increasingly automated, climate-stressed and unpredictable world'.

ICMM is a signatory of the Paris Peace Forum's call to action on the responsible sourcing and production of critical minerals, and has recently highlighted the actions the mining industry can and should take to uphold human rights during the energy transition.

Guiding principles

Balanced

ICMM frequently highlights the longstanding commitment of the mining and metals industry to sustainable development, and the fundamental role the industry has to play in addressing climate change'.

Fact-based ICMM's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused ICMM generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral ICMM generally appears to advocate in favour of technology neutral policy frameworks.

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Appendix A – Summary of association advocacy continued

Minerals Council of Australia

We have found there to be some, non-material, misalignment between the climate policy advocacy of the Minerals Council of Australia (MCA) and BHP's August 2020 Global Climate Policy Standards.

We appreciate MCA's engagement on major policy issues like the Safeguard Mechanism. However, the association has, at times, undertaken advocacy that does not appear to have been appropriately focused (such as commenting on the draft European Union Sustainable Financing Taxonomy) or given appropriate context to the future role of fossil fuels.

On the whole, we believe we suficiently beneit from our membership of MCA to continue with membership at this point in time. In particular, we value the association's: work in driving the Climate Action Plan and Towards Sustainable Mining accountability framework; focus on maintaining the competitiveness of the Australian mining sector in an increasingly challenging domestic and international economic context; and role in helping the mining industry and the broader community navigate the COVID19 pandemic.

Background

Overview

A national and sector-speciic industry association. It has around 120 full and associate members.

2022 membership fee Governance role

US$1 million – US$2.5 million Board member

Policy outcomes

Global agreements MCA has recognised the need for global action and Australia's participation in global agreements – both in principle and in practice.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

MCA has conirmed 'the industry's ambition to achieve net zero emissions by 2050 in support of the goals of the Paris Agreement'. In line with this position, the MCA has: developed and maintained its Climate Action Plan; commenced implementation of the Towards Sustainable Mining framework; contributed to the development of various climate policies and supported efforts to expand the production of critical minerals in Australia.

MCA has welcomed the previous Australian Government's net zero by 2050 target and the current Australian Government's Climate Change Act and legislated target of reducing GHG emissions by 43% on 2005 levels by 2030.

MCA's position statement highlights the importance of pursuing least cost abatement, market-based policy measures, policy certainty and investments in low emission technologies. In line with these positions, the MCA has advocated on various climate policies and related issues.

MCA has advocated in favour of policies that support the development and deployment of pre-commercial technologies – both in principle and in practice.

MCA has supported a range of measures to expand the production of critical minerals in Australia.

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Appendix A – Summary of association advocacy continued

Guiding principles

Balanced

Fact-based

Focused

MCA's advocacy generally appears to be balanced between upholding the competitiveness of Australia's mining industry and highlighting the upside presented by the energy transition.

MCA generally appears to be fact-based in its advocacy. However, at times, the association has used language on the future role of fossil fuels that lacks important context. For instance, MCA commissioned research on future demand for thermal coal that took account of current policy settings, but did not give full consideration to how demand could be affected if governments around the world adopted more ambitious climate polices (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

In December 2020, MCA provided feedback to the European Commission, arguing that the draft European Union Sustainable Financing Taxonomy should treat 'clean energy sources such as nuclear power and carbon capture utilisation and storage (CCUS)' equally as other clean energy technologies. In July 2021, MCA issued a media release highlighting free trade-related concerns with the European Union's proposed Carbon Border Adjustment Mechanism. Regardless of the substance of the underlying claims made by MCA, it is not clear to BHP that either of these interventions in another jurisdiction's policy process represented the best use of the MCA's advocacy efforts.

In 2019, MCA advocated in support of carrying over 'emissions reductions from the irst and second Kyoto commitment periods' to help achieve Australia's 2030 target. In August 2020, following the release of BHP's Global Climate Policy Standards, the MCA noted the 'use of Kyoto carryover credits was an issue for the government'.

Technology neutral MCA generally appears to advocate in favour of technology neutral policy frameworks.

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Mining Association of Canada

We have found there to be alignment between the climate policy advocacy of the Mining Association of Canada (MAC) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A national and sector-speciic industry association. It has around 110 full and associate members.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements MAC's policy principles recognise that 'climate change is a global issue that requires a global solution'. MAC has also expressed support for climate action that is consistent with the aims of the Paris Agreement.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

MAC has expressed support for climate action that is consistent with the aims of the Paris Agreement. In line with this position, MAC has: developed a new Climate Change Protocol under the Towards Sustainable Mining accountability framework; contributed to the development of key emissions reduction policies; and advocated for Canada 'to play a much more signiicant role in providing the materials the world needs to get to net-zero'.

MAC does not appear to have directly commented on the emissions reduction targets or goals set by the Canadian Government.

MAC's policy principles outline the association's views on how the Canadian Government can achieve effective and eficient climate change policy. They include an endorsement of carbon pricing and the need to address competitiveness concerns. In line with these principles, MAC has engaged on various climate policies and related issues.

MAC has advocated (in principle and in practice) for policy measures to support the technologies required to help the mining sector decarbonise.

MAC has frequently advocated for Canada 'to maximize domestic production of low carbon metals and materials needed to meet projected clean technology demand'. MAC has also engaged with the Canadian Government on its proposed approach to a 'people-centred just transition'.

Guiding principles

Balanced

MAC's advocacy generally appears to be balanced between upholding the competitiveness of the Canadian mining sector and highlighting the opportunities presented to Canada by decarbonisation.

Fact-based MAC's advocacy generally appears to be fact-based and free of ambiguous terminology.

Focused MAC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral MAC generally appears to advocate in favour of technology neutral policy frameworks.

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New South Wales Minerals Council

We have found there to be some, non-material, misalignment between the climate policy advocacy of the New South Wales Minerals Council (NSWMC) and BHP's August 2020 Global Climate Policy Standards.

The NSWMC has tended to emphasise the risks associated with the transition of the electricity sector, without engaging during our 2023 industry association review period (at least publicly) with various policy processes designed to mitigate these risks. Furthermore, the NSWMC has not always given appropriate context on the future role or GHG emissions proile of fossil fuels.

On the whole, we believe we suficiently beneit from our membership of the NSWMC to continue with membership at this point in time. In particular, we value the assistance the NSWMC has provided, and continues to provide, as we proceed with our intended managed process to cease mining at New South Wales Energy Coal by the end of FY2030 and prepare for closure.

Background

Overview

A state-based and sector-speciic industry association. It has around 80 full and associate members.

2022 membership fee Governance role

US$500,000 – US$1million Member of the Executive Committee

Policy outcomes

Global agreements NSWMC acknowledges that 'sustained global action is required to reduce the risks of human-induced climate change' and supports 'Australia's participation in global agreements, including the [UNFCCC]'.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

NSWMC's position statement supports 'Australia's participation in global agreements, including the [UNFCCC]', and the 'NSW Government and Australian Government target of reaching net-zero emissions by 2050'. In line with these principles, NSWMC has contributed to the development of emissions reduction policies; and supported efforts by the NSW Government to position the State as a major supplier and processor of critical minerals.

NSWMC's position statement supports the 'NSW Government and Australian Government target of reaching net-zero emissions by 2050'.

NSWMC's position statement maintains that policy frameworks should 'provide for least-cost abatement … and recognise that all sectors of the economy have a role to play in meeting emission reduction goals, including the resources sector'. In line with these principles, NSWMC has engaged on various climate policies and related issues.

NSWMC has advocated in favour of policies that 'the research, development and deployment of new and emerging low emissions technologies' – in principle and in practice.

NSWMC has advocated in favour of reforming the NSW planning regime, with the goal of allowing mining operations 'to amend their existing post-mining approval conditions in response to community needs so local mining communities receive the best possible outcomes once mines reach the end of their operating lives'. Such a change would enable a more community-centric approach to an equitable transition.

NSWMC has also supported efforts by the NSW Government to position the State as a major supplier and processor of critical minerals.

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Guiding principles

Balanced

Fact-based

NSWMC has highlighted the opportunities presented by the energy transition to NSW (in terms of increased demand for critical minerals) and the steps being taken by mining companies to decarbonise.

The association's advocacy on the electricity system, however, tends to have more of a focus on the costs and risks associated with the energy transition, without giving due consideration (at least in public) to the policy solutions needed to ensure a decarbonised grid can supply electricity as cheaply and reliably as possible.

NSWMC has, at times, used language on the future role of fossil fuels that lacks important context. For instance, NSWMC has noted that coal exports are 'likely to contribute strongly to our economy for decades', based on forecasts of coal demand published by the NSW Government and the IEA that appear to be based on current policies. The association does not, however, provide information on how these forecasts could be affected if governments around the world adopted more ambitious climate polices (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

NSWMC's Responsible Mining campaign makes a reference to NSW's 'high quality, low-emissions coal'. This framing could be interpreted as the NSWMC suggesting coal produced from NSW is a source of low GHG emissions energy. If the intent of NSWMC was to highlight that coal produced from NSW results in lower GHG emissions compared to coal produced from other jurisdictions, the association should be clearer in its language.

Focused NSWC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral NSWMC generally appears to advocate in favour of technology neutral policy frameworks.

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Queensland Resources Council

We have found there to be some, non-material, misalignment between the climate policy advocacy of the Queensland Resources Council (QRC) and BHP's August 2020 Global Climate Policy Standards.

In November 2021, the QRC advocated in a manner that presented a misleading view of the electricity system in Queensland.

The Findings and Outcomes section of this Report provides further information with respect to our determination to remove suspension of our membership of the QRC effective 1 June 2023.

Background

Overview

A state-based and sector-speciic industry association. It has around 180 full and services members.

2022 membership fee Governance role

US$500,000 – US$1million1,2 Board member

Policy outcomes

Global agreements The QRC recognises that 'climate change is a critical global challenge' and that climate policies 'must be consistent with Australia's participation in global agreements, including the Paris Agreement'.

Paris Agreement goals

The QRC's position statement supports the aims of the Paris Agreement, 'action to achieve the commitments under the [Paris Agreement]' and 'the [MCA's] industry ambition to achieve net zero emissions by 2050'. In line with these positions, the QRC has contributed to the development of the Queensland Resource Industry Development Plan; and supported efforts by the Australian and Queensland governments to expand the production of critical minerals in the State.

Emissions reduction targets

Least cost abatement

The QRC's position statement supports 'the [MCA's] industry ambition to achieve net zero emissions by 2050'. While the QRC does not appear to have commented on the emissions reduction targets of either the Federal or State governments during our review period, it has acknowledged the need for action to meet 'emissions targets'.

The QRC's position statement supports market-based approaches that prioritise least cost abatement, maintain international competitiveness, are technology neutral, and 'deliver a clear, predictable and long-term price signal'. In line with these principles, the QRC has engaged on various climate policies and related issues.

Pre-commercial technology

Enabling the broader transition

Guiding principles

Balanced

The QRC has advocated for policy measures that support the development and deployment of low emission technologies – in principle and in practice.

The QRC has highlighted the importance of local adaptation planning and supported efforts by the Australian and Queensland Governments to expand the production of critical minerals in the State.

The QRC's advocacy generally appears to be balanced between upholding the competitiveness of the Queensland mining sector and highlighting the opportunities presented to Queensland by decarbonisation. An illustrative example is the QRC response to the Queensland Government's Energy and Jobs Plan. The QRC noted that while the plan to achieve 70% renewable energy by 2032 did 'come with some risk' and would need to be 'managed very tightly', it did provide an 'enormous opportunity' for the resources industry, given the sector supplies many of the raw materials needed to build renewable energy infrastructure.

Fact-based In November 2021, the QRC issued a media release that noted: 'Right now, steel can only be produced commercially by using metallurgical coal, and thermal coal is the only 100 percent reliable way to produce energy in Queensland'. The QRC later updated this release to note that 'thermal coal and gas are the only 100 percent reliable way to produce energy in Queensland'. Even with this update, the statement presents a misleading view of electricity generation in Queensland, as it overlooks the decades-long role played by hydroelectricity in the State (including the 570 MW Wivenhoe pumped storage plant).

Focused The QRC generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral The QRC generally appears to advocate in favour of technology neutral policy frameworks.

1 Fees for the QRC relate to the BHP Mitsubishi Alliance (BMA). BMA is a 50:50 joint venture between BHP and Mitsubishi Development that was formed in 2001. 2 BHP suspended its member of the QRC in October 2021, however we continued to meet our obligations under the QRC constitution, which included the payment of membership fees.

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South Australian Chamber of Mines and Energy

We have found there to be alignment between the climate policy advocacy of the South Australian Chamber of Mines and Energy (SACOME) and BHP's August 2020 Global Climate Policy Standards.

Background

Overview

A state-based and sector-speciic industry association. It has around 200 members.

2022 membership fee Governance role

Less than US$100,000 Board member

Policy outcomes

Global agreements SACOME position statement 'supports the Paris Agreement as a critical element of the global response to climate change'.

Paris Agreement goals

SACOME's position statement supports the aims of the Paris Agreement and the 'target of net zero emissions by 2050'. In line with these positions, SACOME has contributed to the development of climate policies and supported efforts by the South Australian Government to expand the production of critical minerals in the State.

Emissions reduction targets

Least cost abatement

Pre-commercial technology

Enabling the broader transition

SACOME does not appear to have directly commented on the emissions reduction targets of either the South Australian or Australian Governments during our review period. The association has, however, indicated it shares the support of its member companies 'for a target of net zero emissions by 2050'.

SACOME's position statement outlines a number of policy principles. These are centred on achieving least cost abatement and preserving the trade competitiveness of Australian industries, and include an endorsement of market-based mechanisms, carbon pricing, trade and technology neutrality, and effective coordination between climate and energy policy and Federal and State governments. In line with these principles, SACOME has engaged on various climate policies and related issues.

SACOME has advocated (in principle and in practice) for policy measures that support the development and deployment of low emission technologies.

SACOME's position statement highlights the importance of measures to build resilience and support local adaptation. SACOME has also supported efforts by the South Australian Government to expand the production of critical minerals in the State.

Guiding principles

Balanced

Fact-based

Focused

SACOME has adopted a notably constructive approach to climate policy advocacy, with the association advocating for policy proposals to address challenges and opportunities associated with the transition to a low carbon economy of relevance to the mining industry.

SACOME's advocacy generally appears to be fact-based and free of ambiguous terminology.

SACOME generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral SACOME generally appears to advocate in favour of technology neutral policy frameworks.

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United States Chamber of Commerce

We have found there to be some, non-material, misalignment between the climate policy advocacy of the United States Chamber of Commerce (US Chamber) and BHP's August 2020 Global Climate Policy Standards.

We welcome the US Chamber's commitment to climate action and embrace of carbon pricing. However, we believe there is room for the US Chamber to strengthen its position on fuel eficiency standards and mandatory Scope 3 reporting, and ensure it provides appropriate context on the future role of fossil fuels.

On the whole, we believe we suficiently beneit from our membership of the US Chamber to continue with membership at this point in time. In particular, we value the deep expertise and advocacy of the US Chamber on matters relating to iscal policies, trade and geopolitics.

Background

Overview

A national and multi-sector industry association. It has around 3 million members.

2022 membership fee Governance role

US$100,000 – US$500,000 None

Policy outcomes

Global agreements US Chamber has recognised the importance of international action and cooperation. In line with this position, US Chamber welcomed 'President Biden's action to re-join the Paris Climate Agreement'.

Paris Agreement goals

Emissions reduction targets

Least cost abatement

US Chamber has expressed support for 'US participation in the Paris Agreement' and welcomed the Biden Administration's decision to re-join the Paris Agreement. In line with this position, US Chamber has: engaged on climate policy debates; supported efforts to improve access to critical minerals supply; and provided guidance to businesses on how they can accelerate their decarbonisation progress.

US Chamber has advocated for 'reducing emissions as low as we can and fast as we can, while ensuring that any national targets and timetables are realistic, achievable, appropriately account for U.S. economic interests and work to address impacts to trade-exposed, hard-to-adapt and energy intensive sectors'. In line with this position, US Chamber noted the Biden administration's new 2030 target, and expressed its support for the Global Methane Pledge.

US Chamber's position statement highlights the importance of 'acknowledg[ing] the costs of action and inaction and the competitiveness of the US economy', and market-based approaches to emissions reduction. US Chamber has separately indicated that it supports an 'economy-wide carbon price'. In line with these positions, US Chamber has engaged on various climate policies.

Pre-commercial technology

Enabling the broader transition

In March 2020, US Chamber stated that it welcomed the Safer Affordable Fuel-Eficient (SAFE) Vehicles Rule issued by the Trump Administration, on the basis that it appeared to provide 'a workable path forward on a uniied national program that provides regulatory certainty while strengthening fuel economy standards and continuing emissions reductions'. It is not clear, however, that the SAFE Vehicles Rule would have resulted in more cost-effective abatement in the transport sector relative to the more stringent fuel eficiency standards that it replaced – particularly given the reported concerns about the quality of the cost-beneit analysis that underpinned the regulatory change process.

US Chamber has advocated (in principle and in practice) for policy measures that help accelerate the development and deployment of new technologies.

US Chamber has advocated (in principle and in practice) for policy measures that support climate resilient infrastructure. US Chamber has also been a strong proponent of expanding the domestic production and processing of the minerals required to enable the energy transition, with a particular focus on permitting reform.

In June 2022, US Chamber advocated that the Securities and Exchange Commission (SEC) should make Scope 3 reporting voluntary, rather than mandatory, given the dificulties associated with calculating Scope 3 emissions. However, BHP supports the concept of mandatory reporting of Scope 3 emissions, subject to any such requirement relecting the inherent data limitations associated with calculating Scope 3 emissions.

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Guiding principles

Balanced

Fact-based

US Chamber's advocacy generally appears to be balanced between upholding the competitiveness of the US business community highlighting the opportunities presented by decarbonisation. Notably, US Chamber's position statement is underpinned by the recognition that 'inaction is not an option'.

US Chamber generally appears to be fact-based in its advocacy. However, at times, the association used language on the future role of fossil fuels that lacks important context. For instance, in March 2022, the US Chamber noted that 'Oil and natural gas are the primary sources of [reliable] energy, and the Department of Energy forecasts they will remain the most-consumed sources of energy in the U.S. through at least 2050'. The association does not, however, provide information on how this forecast could be affected if governments around the world adopted more ambitious climate polices (such as by noting the outputs of other comparable scenarios) or the technologies that would be required to help align the expected strong demand for fossil fuels with the aims of the Paris Agreement.

Focused US Chamber generally appears to avoid advocacy on issues that may be seen to unduly exacerbate policy tensions.

Technology neutral US Chamber generally appears to advocate in favour of technology neutral policy frameworks.

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