Perpetual Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Perpetual Ltd does not disclose any specific governance process to align its direct or indirect lobbying with its climate objectives. While the company reports that “Perpetual engages through its membership of Investor Group on Climate Change (IGCC) to understand the priorities and activities of that organisation and how that may influence policy, law, or regulation in relation to climate change,” it provides no details on how this engagement is monitored or managed to ensure consistency with its climate strategy. The company also confirms that it does not have “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” stating “No, and we do not plan to have one in the next two years.” Perpetual outlines general ESG engagement responsibilities—asserting that “the responsibility for ESG engagement should fall with those making the investment decisions: the analysts and portfolio managers,” and describing an escalation policy that includes “regular dialogue with senior management and other stakeholders as required” and that “may include contact with the company’s board of directors or relevant regulators, the use of proxy voting or collaboration with other shareholders”—but these measures pertain to investment stewardship of portfolio companies rather than to the governance of its own lobbying activities. Although the company explains that “The policy has been endorsed by the PTCo Investment Committee which is a delegated board committee of various Perpetual entities, including Perpetual Investment Management Limited (PIML),” and that “The Perpetual Private Investment research team is responsible for the Responsible Investment related reporting and review of all Perpetual Private portfolios,” it does not disclose any formal oversight, sign-off, or auditing process for lobbying or policy-advocacy alignment with its climate goals. We found no evidence of a named individual or committee charged specifically with reviewing lobbying activities, nor any described mechanism for trade-association review or direct lobbying alignment. View Sources	E

Overall Assessment

Analysis

Score

None

Perpetual Ltd does not disclose any specific governance process to align its direct or indirect lobbying with its climate objectives. While the company reports that “Perpetual engages through its membership of Investor Group on Climate Change (IGCC) to understand the priorities and activities of that organisation and how that may influence policy, law, or regulation in relation to climate change,” it provides no details on how this engagement is monitored or managed to ensure consistency with its climate strategy. The company also confirms that it does not have “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” stating “No, and we do not plan to have one in the next two years.” Perpetual outlines general ESG engagement responsibilities—asserting that “the responsibility for ESG engagement should fall with those making the investment decisions: the analysts and portfolio managers,” and describing an escalation policy that includes “regular dialogue with senior management and other stakeholders as required” and that “may include contact with the company’s board of directors or relevant regulators, the use of proxy voting or collaboration with other shareholders”—but these measures pertain to investment stewardship of portfolio companies rather than to the governance of its own lobbying activities. Although the company explains that “The policy has been endorsed by the PTCo Investment Committee which is a delegated board committee of various Perpetual entities, including Perpetual Investment Management Limited (PIML),” and that “The Perpetual Private Investment research team is responsible for the Responsible Investment related reporting and review of all Perpetual Private portfolios,” it does not disclose any formal oversight, sign-off, or auditing process for lobbying or policy-advocacy alignment with its climate goals. We found no evidence of a named individual or committee charged specifically with reviewing lobbying activities, nor any described mechanism for trade-association review or direct lobbying alignment.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Perpetual Ltd provides only limited insight into its climate-policy lobbying. The company notes that it took part in a Treasury consultation on climate disclosures and aligns its reporting with frameworks such as the TCFD and ISSB, but it does not name the specific bills, regulations or jurisdictions it sought to influence, nor does it confirm whether these are the only climate-related policy engagements it undertakes. It describes several engagement mechanisms—including participation in industry initiatives, hosting roundtables and workshops, and making submissions to Treasury—but the disclosures do not identify the policymakers or agencies that were the direct targets of these activities. Finally, the company outlines broad objectives such as improving corporate climate disclosure, building capacity and supporting the transition to a low-carbon economy, yet it does not articulate the concrete legislative outcomes, amendments or quantified targets it is advocating for. Together, these omissions mean stakeholders receive only a high-level view of Perpetual’s climate lobbying activities without the detail needed to understand the exact policies, channels and outcomes it seeks.	D