BHP Group Ltd

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